Expert Opinion should be given due importance – Beneficial notification should be given liberal interpretation

It is settled law that the notification has to be read as a whole. If any of the conditions laid down in the notification is not fulfilled, the party is not entitled to the benefit of that notification. The rule regarding exemptions is that exemptions should generally be strictly interpreted but beneficial exemptions having their purpose as encouragement or promotion of certain activities should be liberally interpreted.

This composite rule is not stated in any particular judgment in so many words. In fact, majority of judgments emphasise that exemptio

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