JUDGMENT G. B. PATNAIK, J. - The petitioner's application for refund having been rejected by the Sales Tax Officer by order dated 4th December, 1987 (annexure-4) and the said order having been confirmed by the Additional Commissioner as per his order dated 1st July, 1988 (annexure-5) as corrected by order dated 11th August, 1988 passed by him under annexure-6, the petitioner has approached this Court under article 226 of the Constitution. 2. The petitioner is an assessee under the Orissa Sales Tax Act, 1947 (hereinafter referred to as the "Act") and is a registered dealer. For the assessment year 1986-87, assessment under section 12 of the Act was made by the assessing officer, namely, the Sales Tax Officer, Barbil. The said assessing officer by his order of assessment dated 10th June, 1987 came to hold that excess amount of Rs. 2,194 paid by the dealer is refundable to him as per law. The order of assessment has been annexed as annexure-1. The petitioner then filed an application for refund under section 14 of the Act which has been annexed as annexure-2. The Sales Tax Officer issued a notice to the petitioner under section 12(5) and 12(8) of the Act on a finding that he has reason to believe that the turnover of sales for the year ending 1986-87 on which tax is payable under the Act has escaped assessment. The petitioner was called upon to be present in his office on 6th January, 1988 or to cause to produce the accounts and documents specified therein and to show cause why in addition to the amount of tax that may be assessed, a penalty not exceeding one and a half times of the said amount should not be imposed under sub-sections (5) and (8) of section 12 of the Act. This notice is dated 4th December, 1987 and has been annexed as annexure-3. On the very same day the petitioner's application for refund was also rejected by the same authority on the ground that since proceeding for reassessment under section 12(8) has already been started, the application for refund cannot be allowed. This order has been annexed as annexure-4. The revision petition of the petitioner against the same to the Commissioner of Commercial Taxes was rejected by order dated 1st July, 1988 (annexure-5) and modified by order dated 11th August, 1988 (annexure-6). 3. This order has been annexed as annexure-4. The revision petition of the petitioner against the same to the Commissioner of Commercial Taxes was rejected by order dated 1st July, 1988 (annexure-5) and modified by order dated 11th August, 1988 (annexure-6). 3. The petitioner's case in this writ application is that the order under annexure-4 is per se bad and has been passed mala fide just to avoid the liability to refund and issuance of notice for reassessment under section 12(8) does not come within the purview of the second proviso to section 14 of the Act. Thus, it is the second proviso to section 14 of the Act which crops up for an interpretation in the present case. Second proviso to section 14 of the Act is extracted hereunder its exietiso : "Provided further that no claim to refund of any tax, penalty or interest paid under this Act shall be allowed in cases where there is an order for reassessment, until the reassessment is finalised." It is to be noted that the aforesaid second proviso was not there in the original statute and was inserted by the amendment under Orissa Act 23 of 1983 which was given effect to from 12th August, 1983. In fact, the necessity for the aforesaid amendment arose on account of two Bench decisions of this Court in the case of Orient Paper and Industries Ltd. v. Sales Tax Officer, Sambalpur III Circle, Jharsuguda [1982] 60 STC 211 decided on 27th August, 1981 which was followed by another Bench decision of this Court in the case of Orissa Road Transport Company Ltd. v. Sales Tax Officer, Ganjam I Circle, Berhampur [1983] 54 STC 22 decided on 25th March, 1983. It was held in the aforesaid two cases that notwithstanding the fact that reassessment is yet to be made, the tax paid in respect of the periods, assessment for which is set aside, becomes refundable under section 14 and it can be withheld only in exercise of the power of the Commissioner under section 14-D and not otherwise. In both these cases the State's contention that since the reassessment proceeding was pending, an application for refund could not be entertained was negatived. 4. Mr. In both these cases the State's contention that since the reassessment proceeding was pending, an application for refund could not be entertained was negatived. 4. Mr. Ray, learned counsel for the petitioner, contends that a notice under section 12(8) of the Act is merely an initiation of a proceeding for reassessment and is not an order for reassessment within the meaning of the second proviso to section 14 of the Act and therefore, the said second proviso has no application on mere issuance of a notice under section 12(8). The learned counsel further contends that the power of the Commissioner under section 14-D would become redundant if issuance of a notice by the assessing officer is construed to be an order for reassessment and further the entitlement of an assessee to get the refund pursuant to an order of assessment becomes nugatory on the mere ipse dixit of the assessing officer who may issue notice under section 12(8) of the Act. According to the learned counsel that could not have been the intention of the second proviso to section 14 and even though the plain meaning of the second proviso may confer that meaning, the court should, at the cost of doing violence of the language, interpret the same in a manner which would subserve ends of justice. 5. Mr. A. B. Misra, learned Standing Counsel for the department, on the other hand contends that in view of the unambiguous and plain language used in the second proviso to section 14 of the Act, the moment an order of reassessment is passed, application for refund cannot be allowed until finalisation of the reassessment proceeding. According to the learned Standing Counsel, an order for reassessment starts with initiation of a notice under section 12(8) and culminates in the final order after hearing the parties and in fact the very object for bringing in the second proviso to section 14 of the Act by way of amendment was not to allow any refund in cases where there has been an order for reassessment until the same reassessment proceeding has been finalised. The learned Standing Counsel further contends that a cardinal principle of interpretation of a taxing statute is to give a literal meaning to the words used in the statute and to adhere to the plain grammatical and ordinary sense of the words unless by such adherence some absurdity or inconsistency for rest of the statute arises. It is not the duty of the court to find out the supposed intention of the legislature since the words themselves alone best declare the intention of the law-giver. 6. The rival contentions require careful examination of the statute itself and some of the decisions cited at the Bar. A bare perusal of the second proviso to section 14 of the Act makes it abundantly clear that a claim to refund of any tax paid under the Act shall not be allowed where there is an order for reassessment, until the reassessment is finalised. The language of the second proviso is plain and unambiguous. It conveys the intention of the legislature in no uncertain terms that an application for refund shall not be allowed in a case where there is an order for reassessment, until the reassessment is finalised. It is well-settled that the words of a statute are ordinarily to be understood in the natural, ordinary, popular and grammatical meaning unless such a construction leads to an absurdity or the context or the object of the statute suggests a different meaning. In construing the provision of a statue it is essential for a court, in the first instance, to give effect to the natural meaning of the words used therein, if those words are clear enough. It is only in the case of any ambiguity that a court is entitled to ascertain the intention of the legislature by construing the provisions of the statute as a whole and taking into consideration other matters and the circumstances which led to the enactment of the statute. This being the rule of interpretation, it is not possible for us to accept the contention of Mr. Ray, learned counsel for the petitioner, that the legislature never intended to negate a claim of refund arising out of an order of the assessing officer by mere issuance of a notice for reassessment by the self-same assessing officer. This being the rule of interpretation, it is not possible for us to accept the contention of Mr. Ray, learned counsel for the petitioner, that the legislature never intended to negate a claim of refund arising out of an order of the assessing officer by mere issuance of a notice for reassessment by the self-same assessing officer. If the legislature did intend that which it has not expressed clearly or if the legislature intended something very different, just opposite of what is said, it is certainly not for the judges to invent something which they do not mean within the words of the text. It is not for the judges to supply a meaning by doing violence to the plain language used in a statute howsoever harsh the plain interpretation may be for an assessee. In our considered opinion, the second proviso to section 14 is not susceptible to any other construction than what we have already said notwithstanding the fact that in some cases an assessee getting a right to refund in the order of assessment, loses the said right by the very officer passing an order of reassessment until the said reassessment proceeding is finalised. 7. We also do not find any substance in the other contention of Mr. Ray that section 14-D becomes redundant and nugatory if the second proviso is interpreted in a manner in which we have already interpreted. Section 14-D anthorises the Commissioner to withhold the refund for some time where an order giving rise to refund is the subject-matter of an appeal or other proceeding under the Act. That power, the Commissioner would always possess whenever an order of refund becomes the subject-matter of an appeal or any other proceeding under the Act. This is an enabling power of the Commissioner to withhold refund till such time as he deems proper. But, second proviso to section 14 puts a statutory bar to allow any claim of refund in a case where there is an order for reassessment until the reassessment is finalised. There is no conflict between the second proviso to section 14 and section 14-D and both can harmoniously operate in their respective fields. Accordingly, we do not find any substance in Mr. Ray's contention. 8. There is no conflict between the second proviso to section 14 and section 14-D and both can harmoniously operate in their respective fields. Accordingly, we do not find any substance in Mr. Ray's contention. 8. The only other contention which survives for our consideration is whether a notice under section 12(8) of the Act can be construed to be an order for reassessment within the meaning of the second proviso to section 14. Relying upon a decision of the Calcutta High Court in the case of Nepal Chandra Banerji v. Commercial Tax Officer, Jalpaiguri [1977] 40 STC 23, Mr. Ray contends that an order is always a determination and finality of the proceeding whereas a notice is the beginning of the same and in that view of the matter issuance of a notice cannot be construed to be an order for reassessment. In our opinion, the aforesaid decision is of no assistance in construing the expression "order for reassessment" used in the second proviso to section 14. The legislature has not used the words "order of reassessment" and it is more clear by the expression used in the second proviso "until the reassessment is finalised". It, therefore, clearly stipulates that whenever there is an order for initiation of a reassessment proceeding until the said proceeding is finalised claim of refund cannot be allowed. Issuance of a notice on the assessee under section 12(8) of the Act cannot but be an order for reassessment and therefore, during the continuance of such proceeding until the same is finalised, the second proviso to section 14 would apply and claim of refund cannot be allowed. In this view of the matter, there is no infirmity in the order of the assessing officer passed in annexure-4 as well as in the order of the Commissioner passed in annexure-5. 9. In the result, we do not find any merit in this writ application which is accordingly dismissed, but in the circumstances without any order as to costs. V. GOPALASWAMY, J. - I agree. Writ application dismissed.