DAVE, C.J.—This is writ application under Art.226 of the Constitution of India. 2. The petitioner-firm is a retail pan-bidi dealer and carries on its business at Pali Bazar, Beawar. Under the Ajmer Sales Tax Act, 1955, betel-leaf was a non-taxable commodity. The Rajasthan Sales Tax Act, 1954, which will hereinafter be referred as the Act was extended to the erstwhile State of Ajmer after its merger with the State of Rajasthan on 6th June, 1957. Thereafter, the Assistant Sales Tax Officer, Beawar, issued a notice to the petitioner asking it to get itself registered under the Act. The petitioner accordingly obtained a registration certificate on 1st November, 1957. By a notification No.F.5(51), E&T/58 dated 1st April, 1958, issued by the Government of Rajasthan, the sale of betel-leaves was exempted from sales-tax on the condition that the dealer claiming exemption would obtain valid certificate of exemption for which a fixed annual fee of Rs. 10/- was prescribed. Accordingly, the petitioner obtained the exemption certificate on 22nd August, 1958. The Assistant Sales Tax Officer, Beawar, issued to the petitioner notice No. 3276 dated 24th June, 1959 requiring it to produce its account books in connection with the assessment of the sales-tax under sec. 10 of the Act. He assessed the petitioner to sales-tax by his assessment order dated 3rd July, 1959. 3. The petitioner has produced a copy of the assessment order dated 3rd July, 1959, and it appears from its perusal that it was urged on its behalf that it was not liable to pay any tax on the sale of betel-leaves. Its contention was not accepted by the Assistant Sales Tax Officer and it was held by him that the exemption allowed for betel-leaves did not extend to what he called a processed Pan which, in Hindi, was termed as laga huwa pan. It was observed by him as follows:— "In the case of preparing pan ready for eating there is a series of actions. Not only this, continuous operation or treatment and a chemical process of applying Chuna, Katha and Supari to the betel-leaf, one after the other in an orderly and methodical way is present there. It was observed by him as follows:— "In the case of preparing pan ready for eating there is a series of actions. Not only this, continuous operation or treatment and a chemical process of applying Chuna, Katha and Supari to the betel-leaf, one after the other in an orderly and methodical way is present there. In the circumstances I am of the view that the assessee is a processor and his sales of eatable or ready pan are sales of processed pan and hence attract sales-tax." It was also urged on behalf of the petitioner that even if the application of Chuna and Katha be treated as processing of the betel-leaves, it was not liable to pay tax on the so-called processed pan, because all the commodities used, namely, Chuna, Katha and Supari were tax-paid and they should not be taxed again. This contention was also repelled by observing that "as soon as Chuna, Katha and Supari are applied to betel-leaves, their individual identity is lost". According to the said officer, the processed pan was a commodity in itself different from its constituents and being a separate commodity, it attracted levy of sales-tax. 4. Aggrieved by the said order, the petitioner filed an appeal which was heard by the Deputy Commissioner, Sales Tax ( Appeals ), Jaipur. The appellate authority approved the view taken by the Assistant Sales Tax Officer and dismissed the appeal on 18th May, 1960. 5. The petitioner then filed the present writ application in this Court on 10th October, 1960. It was urged by him that the respondents had committed an error in making a distinction between betel-leaves and what they termed as processed pan and declaring that the latter was a distinct commodity and liable to sales-tax. It was pointed out that no manufacturing or chemical process was used in the preparation of pan and it was neither correct nor proper to use those high sounding terms, simply because Chuna, Katha and Supari or some masalas which are already tax-paid were added to a betel-leaf before it was offered for chewing. It was contended that the respondents had placed a wrong interpretation on the term betel-leaves appearing in the said notification and that they had imposed illegal tax on the petitioner. Hence, it was prayed that a writ of certiorari or any other writ or direction may be issued and the said orders be quashed. It was contended that the respondents had placed a wrong interpretation on the term betel-leaves appearing in the said notification and that they had imposed illegal tax on the petitioner. Hence, it was prayed that a writ of certiorari or any other writ or direction may be issued and the said orders be quashed. It was also proved that the respondents may be directed to refund the tax which was paid by the petitioner on account of the wrong interpretation of the said notification. 6. The writ application is contested on behalf of the respondents and it is urged that the view which they had taken was quite correct and no exception could be taken to it. 7. It would-appear from the said narration of facts that the main question invoved in the present case is the inter-pretation of the term betel-leaves appearing in the notification dated 1st April, 1958, which runs as follows:— "Government of Rajasthan Notification No.F.5(51) E&T/58 Jaipur, April 1, 1958. In exercise of the powers conferred by subsec. (2) of sec. 4 of the Rajasthan Sales Tax Act, 1954 (Rajasthan Act No. XXIX of 1954), the Government of Rajasthan, being of the opinion that it is necessary in the public interest so to do, does hereby exempt the sale of betel-leaves from tax, on the condition that the dealer clai ming exemption holds a valid certificate of exemption for which a fixed annual fee of Rs. 10/ is hereby prescribed. By Order of the Governor Sd/- G.S. Purohit Secretary to the Govt." 8. It is urged on behalf of the petitioner that the Government wanted to give relief to the dealers and consumers of betel-leaves, that betel-leaves are generally not sold in retail in their raw form without the application of Katha, Chuna and Supari and the Assistant Sales Tax Officer should not have interpreted the term betel-leaves in such a narrow sense as to defeat the very purpose of granting exemption to their sale. It is contended that in case of any doubt or ambiguity the taxing Statute must be construed liberally and in favour of the assessee. In support of his contention, learned counsel has referred to the following cases : Upper India Chamber of Commerce Gawnpore vs. Commissioner of Income-tax, C. P. & U. P. Lucknow(l), The Commissioner of Agricultural Income-tax, West Bengal Vs. In support of his contention, learned counsel has referred to the following cases : Upper India Chamber of Commerce Gawnpore vs. Commissioner of Income-tax, C. P. & U. P. Lucknow(l), The Commissioner of Agricultural Income-tax, West Bengal Vs. Raja Jagdish Chandra Deo Dhabal Dab, Chilkigarh, District Midnapore(2), and Commissioner of Income-tax, Madras Vs. K. E. Sumdara Mudaliar(3). 9. It is further contended that "betel-leaves were held to be equivalent to pan in Kokilram Vs. Province of Bihar(4), Messrs. Dharmadas Paul Vs. Commissioner of Commercial,Tax, West Bengal (5) and Bhairondan Tolaram Vs. State of Rajasthan(6) It has been vehemently argued that both the respondents had themselves.conceded that Chuna, Katha and Supari are masalas which are generally added to a green betel-leaf in order to make it flavoury and eatable, that they were already tax-paid, that the betel-leaves were expressly exempted from the tax by the said notification that no particular manufacturing process was necessary for making them eatable and that both the respondents had committed a serious error in holding that the so-called processed pan was a commodity different from the betel-leaves. 10. In reply, it is urged by the respondents learned counsel that it has been held by this Court in Indersingh Vs. Sales Tax Officer, Jodhpur(7) that an exemption clause must be interpreted strictly and that the respondents had, therefore, committed no error in holding that the term betel-leaves appearing in the said notification was confined to only those betel-leaves to which nothing was added and that the processed pan was a different commodity from the betel-leaves. He has relied on the following cases : State of Travancore-Cochin Vs. Shanmugha Vilas Cashewnut Factory, Quilon (8), Messrs. Anwarkhan Mahboob Co., Vs. The State of Bombay(9), Messrs. Chhotabhai Jethabhai Patel and Co. Vs. State of Uttar Pradesh(lO), Kapildeoram Baijnath Prosad Vs. J.K. Das (11), Yamsani Sudarsanam Vs. The State of Andhra Pradesh(12) and Commissioner of Sales Tax, Maharashtra State, Bombay Vs. Fairdeal Corporation Ltd.(13). 11. Before proceeding to interpret the term betel-leaves appearing in the said notification, it may be observed that in Indersingh Vs. Sales Tax Officer, Jodhpur(7), the assessee claimed exemption of sales-tax on Durries. The Sales Tax Officer disallowed it holding that Durries were not included in the category of handloom cloth. The question, which arose for determination before the Court was, whether a Durri was included in the term handloom cloth. Sales Tax Officer, Jodhpur(7), the assessee claimed exemption of sales-tax on Durries. The Sales Tax Officer disallowed it holding that Durries were not included in the category of handloom cloth. The question, which arose for determination before the Court was, whether a Durri was included in the term handloom cloth. It was held that it would not be proper to give the term cloth such a wide meaning as to bring a Durri within its ambit. It is obvious that the facts of the said case were very different from those of the present one. It was held that Durri was used as a carpet and not as a cloth and simply because it was also prepared on a handloom, it could not be included within the ambit of the term handloom cloth. It is obvious that in the said case, the petitioner wanted to extend the scope of the term "handloom cloth" to a grossly unreasonable extent and so his arguments did not find favour with the learned Judges and it was held that the Durri was outside the scope of the term handloom cloth. 12. Learned Deputy Government Advocate has laid stress upon the following observations made in Kapildeoram Baijnath Prosad Vs. J.K. Das (11) and to which pointed reference was made by the learned Judges in the above case: "All exemptions from taxation must be strictly construed and must not be extended beyond the express requirements of the language used. The taxation laws are not in the nature of penal laws; they are substantially remedial in their character and are intended to prevent fraud, suppress public wrong and promote the public good. They should, therefore, be construed in such a way as to accomplish those objects." The learned Deputy Government Advocate seems to be of the view that this observation is in conflict with the views expressed in the cases relied upon by learned counsel for the petitioner and it is prayed that we should not depart from the view which has been adopted by another Bench in the said case. Before expressing our views, it would be proper to refer to the following cases relied upon by the petitioners learned counsel: In Upper India Chamber of Commerce, Cawnpore Vs. Before expressing our views, it would be proper to refer to the following cases relied upon by the petitioners learned counsel: In Upper India Chamber of Commerce, Cawnpore Vs. Commissioner of Income-tax, Lucknow (1), Verma J., to whom the case was referred on account of difference of opinion between Iqbal Ahmad C. J., and Braund J., concurred with the view of Iqbal Ahmad C. J., who had observed as follows: "In the present case, we are concerned with the interpretation of an exemption clause in a taxing statute and that clause must be, as far as possible, liberally construed and in favour of the assessee, provided no violence is done to the language used." 13. In the Commissioner of Agricultural Income-tax, West Bengal Vs. Raja Jagdish Chandra Deo Dhabal Dab(2), it was observed that "where an exemption is conferred by a statute by an exemption clause, that clause has to be interpreted liberally and in favour of the assessee but must always be without any violence to the language used." 14. In the Commissioner of Income-tax, Madras Vs. K. E. Sundara Mudaliar(3), the learned Judges after referring to number of English cases, observed that "exemption from tax granted by the statute should be given full scope and amplitude and should not be whittled down by importing limitations not inserted by the Legislature. 15. It may be observed that, in our opinion, there is no essential difference between the view expressed by this Court in Inder Singh Vs. The Sales Tax Officer, Jodhpur(7) and the view taken in the last three cases, referred above, and relied upon by learned counsel for the petitioners. It is interesting to point out that in Kapildeoram Baijnath Prosad Vs. J. K. Das(ll) on which reliance was placed by this Court in Indersingh Vs. The Sales Tax Officer, Jodhpur (7), the question before the Court was whether chira and muri were included in "cereals" and it was held that they were included. It is common knowledge that chira and muri are prepared from rice after it is put to certain processes and yet the learned Judges held that they were not excluded from the ambit of the term "cereals". Thus, although the learned Judges made the said observation, they were not reasonably harsh in its application. It is common knowledge that chira and muri are prepared from rice after it is put to certain processes and yet the learned Judges held that they were not excluded from the ambit of the term "cereals". Thus, although the learned Judges made the said observation, they were not reasonably harsh in its application. In Indersingh vs. The Sales Tax Officer, Jodhpur (7), the learned Judges had to refer to the said observation because the petitioner wanted to stretch the scope of exemption clause to unreasonable length. In our opinion, every observation, which is made by the Court, should be understood in the context of the facts and circumstances of that particular case. In Indersingh vs. The Sales Tax Officer (7), the tax-payer wanted to stretch the scope of the term handloom cloth to an unreasonable length and, therefore, the Court made its remarks from that angle of vision and observed that exemption clause "must not be extended beyond the express requirements of the language used." 16. On the other hand, in the three cases relied upon by the petitioners learned counsel, the taxing authorities had placed a very narrow interpretation on the exemption clause and hence the Court made its observation from the other angle and remarked that it should be interpreted liberally in favour of the assessee but without doing any violence to the language used. 17. The real import of all the observations made in the said cases is that the exemption clause appearing in taxation laws should be reasonably interpreted. The interpretation should neither be so liberal that it may promote fraud and open flood-gates for the tax-payers to evade the tax by subtle and dishonest devices, nor should it be so narrow and un-reasonable that the remedy provided by the Legislature becomes only nominal and the very object which it is sought to accomplish is defeated. It should be given its full and reasonable scope and amplitude so long as no violence is done to the language used and the exemption should not be whittled down by importing limitations not inserted or contemplated by the Legislature. 18. We have now to see in this light as to what should be the reasonable interpretation of the term betel-leaves appearing in the said notification. 19. 18. We have now to see in this light as to what should be the reasonable interpretation of the term betel-leaves appearing in the said notification. 19. It may be observed that although a number of cases have been cited on either side, none of them has a direct bearing on the controversy which has been raised in this case. In Bhairondan vs. State of Rajasthan(6) relied upon by learned counsel for the petitioner, the question involved was whether the betel-leaves came within the ambit of eatable vegetables and it was held that the word vegetables was used in the Schedule in its narrowed sense meaning only those classes of vegetables which were grown in kitchen gardens to supplement the food and, therefore the term "betel-leaves" fell outside the admit of the term "vegetables". 20. In Kokilram vs. Province of Bihar(4) also, it was held that the word "vegetables" used in the notification was used in the limited sense of plants cultivated for food and did not include "betel-leaves". 21. Again, in Messrs Dharmadas Paul vs. Commissioner of Commercial Tax, West Bengal (5), it was held that the pan or betel-leave was not a vegetable within the meaning of Item 6 of the Schedule appended to the Bengal Finance (Sales Tax) Act, 1947. 22. It is, no doubt, true that the words "pan" and "betel leaf" were used as synonymus in the last two cases, but there was no controversy, as in the present case, as to the question whether, the term "betel-leaves" also included leaves after the Chuna and Katha were applied to them. These cases are, therefore, not very helpful for resolving the dispute which has been raised before us. We have, therefore, to see what should be the reasonable interpretation of the term "betel-leaves" appearing in the said notification. 23. We have given our earnest consideration to the views expressed by the Assistant Sales Tax Officer and the Deputy Commissioner and with due respect to them, we find it very difficult to accept the very restricted meaning which they have tried to give to the term "betel-leaves". If their interpretation is accepted, it would mean that only those betel-leaves would be saved from the tax which are not consumed after the application of Chuna and Katha. 24. If their interpretation is accepted, it would mean that only those betel-leaves would be saved from the tax which are not consumed after the application of Chuna and Katha. 24. Now, it is common knowledge that the betel leaves are not used without the application of Chuna and Katha generally except for medicinal purposes. In other words, an insignificant quantity of betel-leaves is, no doubt, used as a vehicle for administering certain drugs of medicines by Vaids. It is likely that some negligible quantity of such leaves might be used for some other purposes also, but the vast bulk of betel-leaves are used only after the Chuna and Katha are applied to them. If the authorities, which issued the notification, meant to exempt only that negligible quantity of betel-leaves from taxation which is used without Katha and Chuna, there was nothing to prevent them from saying so in express terms. We are inclined to think that when the sale of betel-leaves was exempted by the Government of Rajasthan from Sales-tax, it meant to exempt the entire bulk of betel-leaves from the payment of tax. If this notification is held to apply only to that number of betel-leaves which are used without the application of Chuna and Katha, the entire purpose of exemption would be defeated, because the number of quantity of such leaves would almost be negligible. The respondents have laid great stress on the fact that the betel-leaves ready for eating have to undergo a series of actions and a chemical process. In our view, it looks very high sounding to use the word process for the mere application of a very small quantity of Chuna and Katha to a betel-leaf. It may be pointed out that the betel-leaf even after the application of Chuna and Katha does not lose its original character of a leaf. It is neither boiled nor parched nor dehydrated, but it is consumed in the same raw condition as it is in before the application of Chuna and Katha. All that is done is that a very small quantity of Chuna and Katha is applied and a few pieces of areca nut or some other flavouring article like cardamom etc. is put in to make it more tasteful. To say that the processed pan is a different commodity from the betel-leaf is, in our opinion, not quite correct. 25. All that is done is that a very small quantity of Chuna and Katha is applied and a few pieces of areca nut or some other flavouring article like cardamom etc. is put in to make it more tasteful. To say that the processed pan is a different commodity from the betel-leaf is, in our opinion, not quite correct. 25. The learned Deputy Government Advocate has referred to State of Tra-vancore-Gochin vs. Shanmugha Vilas Cashewnut Factory, Quilon (8). In that case the question before their Lordships was, whether the transaction of cashewnuts purchased by the respondent came within the scope of Articles 286(l)(b) of the Constitution of India. The observations made in that case have no direct bearing on the controversy which has been raised before us. Learned counsel has referred to this case in order to point out that the raw cashewnuts and the kernels manufactured out of them were held to be commercially different commodities. In our opinion, this case is not helpful to the respondents, because it was clearly pointed out in that case that the kernels were taken out by various processes, partly mechanical and partly manual. In the present case, as we have already pointed out, the betel leaves do not undergo any mechanical or manual process so as to extract anything like juice etc. from them. They continue to be betel-leaves even after the application of Chuna and Katha. These things are added to the betel leaves only to make them eatable and their character is not changed. 26. The learned Deputy Government Advocate has next referred to Messrs Anwarkhan Mahboob Co. vs. The State of Bombay (9). In that case, the petitioner carried on the business of manufacture of Bidis in the State of Madhya Pradesh after purchasing raw tobacco from the cultivators in the State of Bombay. A question arose whether the tobacco which was delivered in the State of Bombay, was delivered for the purpose of consumption and whether the purchase fell within the meaning of explanation to Art.286 (1) of the Constitution of India. It was found that the petitioner used to subject raw tobacco to certain processes leading to its conversion into "Bidi pattis", by getting the stems and dust removed from the leaves for immediate use in the manufacture of Bidis before they sent to the State of Madhya Pradesh where Bidis were manufactured. It was found that the petitioner used to subject raw tobacco to certain processes leading to its conversion into "Bidi pattis", by getting the stems and dust removed from the leaves for immediate use in the manufacture of Bidis before they sent to the State of Madhya Pradesh where Bidis were manufactured. It was in those circumstances that it was held that the raw tobacco and bidi patti were distinct and different commercial articles. It would suffice to say that this case is again of little help to the respondents, because a green-betel-leaf is not converted into something else. On the other hand, it continues to remain in the same green and fresh condition even after the application of Chuna and Katha till the time it is actually eaten by the consumer. 27. Another case on which reliance is placed by the learned Deputy Government Advocate is Messrs. Chhotabhai Jethabhai Patel & Co. vs. State of Uttar Pradesh (10). In that case, their Lordships made a distinction between tobacco as it was defined, and hand-made bidis and the observations made therein are of no help for resolving the question which has been raised before us. 28. Learned counsel has also referred to Jethmal Ramswarop vs. The State of Rajasthan (14). In that case, it was argued by the petitioner that misri-patasa etc. were not liable to tax, because sales-tax was already paid on sugar. This contention was not allowed. It may be pointed out that in the said case, it was urged on behalf of the State that the writ application was not maintainable at that stage and this preliminary objection was allowed. After discussing this point at length, it was observed only by way of passing, at the end of the judgment, that even on merits there was no force in the applicants contention because misri-patasa etc. were not merely sugar. It would bear repetition to point out that the observations made in a particular case have to be understood in the context of the facts and circumstances of that case and such an observation cannot be applied to another case by ignoring the background in which it is made. 29. The learned Judges in that case did not give any reasons because the preliminary objection was allowed. 29. The learned Judges in that case did not give any reasons because the preliminary objection was allowed. Secondly, it seems to have weighed with the learned Judges that misri and patasa were not sold in the same form as sugar. 30. In the case of betel-leaves, we have already pointed out that there is no change in its original form even by the time it is consumed. 31. He has next referred to Firm Jaswant Rai Jainarain vs. Sales Tax Officer (15). In that case, it was held by the learned Judges that "where a dealer takes handloom cloth and either cuts it into specific sizes or manufactures them into specific sizes, so that the pieces can be used as saris, bed covers, lihafs (quilt covers) etc. and then prints them so that they can be readily used for the purpose for which they are meant, the articles sold by dealer are clothes or garments and cannot be treated as cloth manufactured on handlooms within the meaning of the Notification. It is obvious that the distinction pointed out by the learned Judges in the said case is hardly of any avail to respondents in the present case. 32. He has also referred to M.A. Ganapathy Iyer vs. Hyderabad State (16). In that case, it was held that merely because rice was mentioned as one of the items exempt from sales-tax, any form of rice such as idlies and dosas should also be deemed to be exempt from sales-tax. This case is also of no help to the respondents because although rice may be one of the main constituents of idlies and dosas they are not the same things as rice. 33. In the end, the learned Deputy Government Advocate has referred to a Notification of 2nd June, 1962, which runs as follows: "Government of Rajasthan (Excise & Taxation Department) NOTIFICATION No. F. 5(43) E & T/62 Jaipur, June 2, 1962 In exercise of the powers conferred by proviso to sub-sec. (1) of sec. 3 of the Rajasthan Sales Tax Act, 1954 (Rajasthan Act No. 29 of 1954), the State Government hereby specifies, for the purpose of clause (a) of the said sub-section, Rs. 10,000/- to be the limit in respect of manufacturers of goods of the classes specified below, namely: 1. Pan (processed betel) 2. Footwear of all kinds. (1) of sec. 3 of the Rajasthan Sales Tax Act, 1954 (Rajasthan Act No. 29 of 1954), the State Government hereby specifies, for the purpose of clause (a) of the said sub-section, Rs. 10,000/- to be the limit in respect of manufacturers of goods of the classes specified below, namely: 1. Pan (processed betel) 2. Footwear of all kinds. By Order of the Governor, S. P. Singh Bhandari, Secretary to the Government" 34. On the basis of this notification, it is contended that if the Government meant to exempt processed pan by the notification dated 1st April, 1958, it would not have issued this notification in respect of processed betel. It is pointed out that this notification fixes the limit of Rs. 10,000/- and a person who deals in processed pan and whose total turnover does not exceed Rs. 10,000/- would not be required to pay sales-tax. It may be observed that the notification which was issued on 2nd June, 1962 cannot have retrospective effect because it has not been made applicable retrospectively. Moreover, this notification does not modify the provisions of the first notification by itself. The present petitioner filed this writ petition in October, 1960 and the respondents filed their reply on 1st March, 1961 and the subsequent notification of this nature made by the Government which does not expressly tend to modify the first notification of 1st April, 1958, cannot be availed of, for resolving the controversy before the Court. 35. To sum up the case, the betel-leaves to which Chuna and Katha are applied do not fall outside the scope of the term "betel-leaves" used in the notification of 1st April, 1958 and, in our opinion, they are as much exempt from sales-tax as the betel-leaves to which Chuna and Katha are not applied. 36. The writ application is, therefore, allowed and the impugned orders of the Assistant Sales Tax Officer and the Deputy Commissioner, Sales Tax (Appeals), are hereby quashed, so far as they relate to taxes assessed with effect from 1st April, 1958. The tax realised from the petitioner on the sales of the betel-leaves after 1st April, 1958, should be refunded to it. The petitioner will receive its costs from the respondents.