JUDGMENT The judgment of the Court was delivered by S. W. PURANIK, J. - The first two petitioners herein are oil refineries and are challenging the interpretation of section 2(12A) of the Bombay Sales Tax Act, 1959. Admittedly, the petitioner are dealing in the manufacture of edible oil as well as non-edible oil and they also deal with the activity of manufacturing oil by crushing oil seeds. The petitioners also manufacture cakes, refined oil and soaps. One of the other activities of the petitioners-refineries is that they procure washed cotton seed oil and convert it into refined cotton seed oil. 2. The controversy centres around the question whether the petitioner unit could be termed as "edible oil unit" within the meaning of section 2(12A) of the Bombay Sales Tax Act, 1959, as far as the activity of the petitioners of procuring washed cotton seed oil and converting it into refined cotton seed oil is concerned. The relevant section which falls for interpretation is as follows : "2. (12A) 'Edible oil unit' means an eligible unit engaged in - (i) delinting, decorticating or processing of groundnuts or other oil seeds; (ii) crushing of groundnuts or other oil seeds and manufacture of edible oil; (iii) refining of edible oil; or (iv) hydrogenation of edible oil." After all the challenges to the Ordinance promulgated on 24th May, 1985 were exhausted and it was held by the High Court that the "New Act" has come into force with effect from 1st August, 1985 prospectively, the tax exemption or tax assessment in respect of edible oil units was to be done as per the definition provided under section 2(12A) of the said Act. Therefore, we need not go into the background of the entire scheme of the Act as well as the circumstances under which the petitioners were encouraged to start these industrial units in a backward area of the State by offering of exemption of sales tax under the Bombay Sales Tax Act. 3. Be it as it may, after the new Act came into force, the petitioners raised a dispute before the Commissioner of Sales Tax under section 52 of the Bombay Sales Tax Act (annexure F to this petition). 3. Be it as it may, after the new Act came into force, the petitioners raised a dispute before the Commissioner of Sales Tax under section 52 of the Bombay Sales Tax Act (annexure F to this petition). It was contended on behalf of the petitioners that since the washed cotton seed oil or cotton seed oil (washed grade) is non-edible oil as held by the Government itself, the manufacture of refined cotton seed oil from such a non-edible oil would not be covered by the definition of "edible oil unit" under section 2(12A) of the Bombay Sales Tax Act. This matter was taken up by the Deputy Commissioner of Sales Tax, Nagpur Division, Nagpur. He also went to the spot where the refineries were situated and found that the petitioner itself purchases washed cotton seed oil and puts it through refining process and the ultimate product obtained is refined cotton seed oil. Further, by his order dated 30th May, 1986, the Deputy Commissioner of Sales Tax, Nagpur Division, Nagpur, held that since the finished product and the commodity after refining is a completely new one and for a different commercial purpose, the petitioners are manufacturing edible refined cotton seed oil, and, therefore, the petitioners' unit falls under the category 2(12A)(ii) and (iii) of the Bombay Sales Tax Act, i.e., "refining and producing of edible oil" and it is in that even that the unit will have to be made assessable to sales tax even for production of such refined cotton seed oil. It is this order at annexure G which is impugned by the petitioners in this petition. 4. Shri V. R. Manohar, Advocate for the petitioners, pointed out that a plain reading of section 2(12A) of the Bombay Sales Tax Act stating definition of "edible oil unit" would clearly show that it is only four types of activities which are covered for the purpose of finding out whether a particular unit is an "edible oil unit" or not. It is an admitted position that items (i) and (iv) are not the activities which are carried out in the oil refineries of the petitioners. Even according to the Commissioner of Sales Tax, the petitioners' unit fall under (ii) and (iii) of the said items of section 2(12A) of the Bombay Sales Tax Act. It is an admitted position that items (i) and (iv) are not the activities which are carried out in the oil refineries of the petitioners. Even according to the Commissioner of Sales Tax, the petitioners' unit fall under (ii) and (iii) of the said items of section 2(12A) of the Bombay Sales Tax Act. Therefore, according to Shri V. R. Manohar, learned counsel for the petitioners, for including the unit as an edible oil unit, the petitioners must be carrying on the activity of crushing of groundnuts or other oil seeds and manufacture of edible oils. He further contended that in so far as the activity of refining the cotton seed oils is concerned, the petitioners procure the said raw material, viz., washed cotton seed oil, from the dealers, and then covert it into refined cotton seed oil. Therefore, there is no activity of crushing groundnuts or cotton seeds while refining the said oil. Further, he pointed out that office of the Commissioner of Sales Tax has taken the decision that washed cotton seed oil is a non-edible oil. If that be so, then it was urged that the interpretation our given by the Deputy Commissioner of Sales Tax at annexure G is totally erroneous and unsustainable and is liable to be quashed. He also pointed out that, in that event, the petitioners' unit cannot be termed as "edible oil unit" when it deals with the activity of merely refining the washed cotton seed oil into refined cotton seed oil, and the petitioners' unit for that activity would be exempted from sales tax as per the scheme for which the petitioners had started the said unit sometime during 1979-83. Further, the petitioners would be entitled to the time-bound exemption provided under the Bombay Sales Tax Act for the agreed period. 5. On the other hand, the learned Government Pleader, Shri M. A. Garud, supported the impugned order and contended that since the product which is manufactured in the petitioners' unit is an edible oil the entire unit must be termed as an "edible oil unit". Mr. Garud also suggested that since the State of Maharashtra is also a respondent and is yet to file the return, the matter may be postponed so as to find out whether the State Government has some other reasons than those stated in the impugned order of respondent No. 3. 6. Mr. Garud also suggested that since the State of Maharashtra is also a respondent and is yet to file the return, the matter may be postponed so as to find out whether the State Government has some other reasons than those stated in the impugned order of respondent No. 3. 6. At the outset, we must point out that this request by Shri Garud on behalf of the Government cannot be granted for the simple reason that the rule was made returnable on 26th of August, 1986 and that the case has been adjourned from time to time for final hearing. Moreover in matters of taxation laws where a particular entry or definition of the said Act has been interpreted then the State Government cannot substitute those reasons by some other reasons to substantiate or validate the conclusions. 7. Coming back to the merits of the present case, the short point involved, therefore, is whether the petitioner's unit, which manufactures edible oils as well as non-edible oils and non-edible products can be bifurcated into two or three activities and whether it can be said that for a particular activity the petitioners' unit is not an edible oil unit under section 2(12A) of the Bombay Sales Tax Act. 8. It is an admitted position that the petitioners are manufacturing oil by crushing oil seeds. If that be so, then the oil manufactured after crushing oil seeds is edible oil within the provisions of the Bombay Sales Tax Act and, in that case, the said unit would be squarely covered under section 2(12A)(ii) of the said Act and would be liable for sales tax on that product. In so far as the petitioners' unit dealing with the activity of refining washed cotton seed oil into refined cotton seed oil is concerned, the question that arises is whether this activity would be covered by the definition of "edible oil unit". A close look at section 2(12a), item (ii) and (iii), would show that what is required is either "crushing of groundnuts or other oil seeds and manufacture of edible oil" or "refining of edible oil". A close look at section 2(12a), item (ii) and (iii), would show that what is required is either "crushing of groundnuts or other oil seeds and manufacture of edible oil" or "refining of edible oil". That means to come within item No. (ii), both the activities of crushing of nuts or oil seeds and manufacture of edible oil will have to be carried out in continuation means the same oil received by crushing will be refined which would make it an "edible oil received by crushing will be refined which would make it an "edible oil unit" as defined under section 2(12A) of the Bombay Sales Tax Act. It was urged on behalf of the respondents that the words "and" used under item No. (ii) should be construed as "or" and that either of the activities of crushing or manufacture of edible oil should be enough to bring the suit under the definition of "edible oil unit". 9. We are afraid that such an interpretation by construing something which is not in the statute would not be the correct interpretation. It has been stated time and again that the general rule is that a taxing statute should be construed strictly, that is, a person should not be taxed unless the words of the statute unambiguously impose the tax on him. In a taxing statute one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can only look fairly at the language used. Moreover, when the definition clearly states that an edible oil unit means the following ...... it is an inclusive definition and it is only those activities which are stated in the definition which can constitute "edible oil unit" excluding all other possibilities. Thus, item No. (ii) of section 2(12A) would only mean that both the activities of crushing of groundnuts or other oil seeds and manufacture of edible oil if carried out in continuation means the same oil received by crushing will be refined then the said unit will be covered by that item, i.e., "edible oil unit". 10. We have to then find out whether the petitioners' unit is covered by item No. (iii) of section 2(12A) of the Bombay Sales Tax Act. 10. We have to then find out whether the petitioners' unit is covered by item No. (iii) of section 2(12A) of the Bombay Sales Tax Act. It is an admitted position, even as per the statement in the impugned order, that the petitioners purchase their raw materials, i.e., washed cotton seed oil, and then refine it into the refined cotton seed oil in their unit. Washed cotton seed oil has been held to be a non-edible oil as per the order of the Commissioner of Sales Tax, Bombay (annexure E). It is, therefore, obvious that the petitioners' unit is not refining edible oil, but non-edible oil and in that case also, their activity would not fall under item No. (iii) of section 2(12A) of the Bombay Sales Tax Act. the reasons given by the Deputy Commissioner of Sales Tax, respondent No. 3, that because the finished produce is edible oil the petitioners' units are "edible oil units", are not acceptable to us in view of the plain definition of "edible oil units" as per section 2(12A) of the Bombay Sales Tax Act. 11. The impugned order is not, therefore, sustainable and will have to be quashed, as per prayer (a) of this petition, and reliefs granted as per prayer clause, clause (a). Before we conclude, however, we would like to clarify that the petitioners admittedly carry on the activity of crushing of oil seeds into edible oil and that activity would certainly be covered by section 2(12A) of the Bombay Sales Tax Act and liable for taxation under the said Act. The above ruling is only in so far as the activity of the petitioners of converting the washed cotton seed oil into refined cotton seed oil is concerned. In that even, a further relief of a restricted nature will have to be granted to the petitioners. The eligibility certificate granted in favour of the petitioners' unit, which covers different activities, would hereafter stand restricted only to the extent of the activity of refining washed cotton seed, oil into refined cotton seed oil and activities not covered by the definition of "edible oil unit". For the rest of the activities, the petitioners' eligibility certificate shall stand surrendered. The eligibility certificate granted in favour of the petitioners' unit, which covers different activities, would hereafter stand restricted only to the extent of the activity of refining washed cotton seed, oil into refined cotton seed oil and activities not covered by the definition of "edible oil unit". For the rest of the activities, the petitioners' eligibility certificate shall stand surrendered. If the authorities so desire they may accept the surrendering of the entire eligibility certificate and issue fresh eligibility certificate and fresh entitlement only in so far as the activity of conversion of washed cotton seed oil into refined cotton seed oil is concerned, and activities not covered by the definition of "edible oil unit". 12. In the result, the Writ Petition No. 1280 of 1986 is partly allowed. Rule is made partly absolute as per the above directions. In the circumstances of the case there shall be no order as to costs. Writ petition partly allowed.