JUDGMENT : B.L. Hansaria, C.J. - The four writ petitioners are engaged in the work of manufacturing Chuda. Their case is that under the Industrial Policy Resolution of 1986, they were entitled to certain incentives which are sought to be denied by Annexure-7 dated 27th March, 1990. This action of the Government has been assailed in these petitions. 2. Shri Lal appearing for the petitioners contends that by relying on the promise held out in the aforesaid policy resolution, the petitioners had set up units for manufacturing Chuda some time in 1989 and as the incentives were to be made available for a period of five years from the date of production, denial of the same before expiry of the aforesaid period is hit by the principle of promissory estoppel. As to the applicability of this doctrine, Shri Patnaik, learned Standing Counsel for the Department, states that the representation must have been unambiguous which must have been reasonably understood as a promise by the person to whom it is made, as stated in Halsbury's Laws of England, 4th Edn.,Vol.16, p.1071,. para 1595, quoted in para 27 of Delhi Cloth and General Mills Ltd. Vs. Union of India (UOI). This submission has been advanced by the learned counsel because the industrial policy resolution is not applicable to a rice mill. The learned counsel states that a unit producing Chuda has to be regarded as a, rice mill and the petitioners understood it to be so which would appear from their applications for obtaining permits to establish rice mills. The licence issued to the petitioners (Annexure-2) speaks about a rice mill producing Chuda. In this connection, our attention is also invited by Shri Patnaik to the definition of 'rice mill' as appearing in Section 3(i)of the Rice Milling Industry (Regulation ) Act, 1958 which states that the expression 'rice mill' means the plant and machinery and the premises including the precincts thereof, in which or in part of which rice milling operation is carried on. We are then referred to Section 3(d) which has defined 'milling rice' meaning, inter alia, recovering rice or any product thereof from paddy. It is stated by Shri Patnaik that Chuda is a product of paddy and as such any mill producing Chuda should be regarded as a rice mill. But then, the definition of 'milling rice' speaks about the recovery of rice 'or any product thereof. It is stated by Shri Patnaik that Chuda is a product of paddy and as such any mill producing Chuda should be regarded as a rice mill. But then, the definition of 'milling rice' speaks about the recovery of rice 'or any product thereof. We do not think if Chuda can be said to be a product of rice, though it is a product of paddy. We would, therefore, be hesitant to hold that a unit producing only Chuda could be called rice mill within the meaning of Section 3(1) of the Rice Milling Industry (Regulation) Act, 1958. 3. In view of the above, we feel inclined to hold that the petitioners understood the Industrial Policy Resolution of 1966 not to exclude a mill producing Chuda. It is not in dispute that the units of the petitioners have been licensed only to manufacture Chuda as would appear from Annexure-1. In this connection, Shri Lal has also drawn our attention to a decision of Madhya Pradesh High Court in Naha Poha-Udyog v. State of M. P. (1990) 34 STC 265 in which a Division Bench had examined the question as to whether 'poha mill' could be included in the expression 'rice mill' as defined in Section 3(1) of the aforesaid Act. It may be stated that poha is the local word for flattened rice in Madhya Pradesh as Chuda in this State. The Bench took the view that the process of manufacturing poha is different from that of milling rice from paddy. In rice milling operation, grain is separated from its chaff, whereas in poha-making operation, paddy is boiled and levelled before being converted into poha or flattened rice, it was, therefore, stated that in common parlance, poha is treated as a different commodity from rice. It was also observed that unless there is any ambiguity in the language employed in the statute, the Courts adopt literal construction if It does not lead to an absurdity and where a provision of law is capable of two interpretations, the Courts prefer the one in favour of tax-payers. It was also observed that unless there is any ambiguity in the language employed in the statute, the Courts adopt literal construction if It does not lead to an absurdity and where a provision of law is capable of two interpretations, the Courts prefer the one in favour of tax-payers. Shri Lal has also referred us to what has been slated at page 51 of Maxwell's Interpretation of Statutes, 11th Edn., which is to the effect that whenever a statute or document is to be construed, it must be construed not according to the mere ordinary general meaning of the words, but according to the ordinary meaning of the words as applied to the subject matter with regard to which they are used. It is contended by the learned counsel that if the idea behind the Industrial Policy Resolution is kept in mind, which is to give a fillip to Industrialisation improving the economic condition of the State, we should not exclude any category of industry from the same unless the strict letter of the policy calls for the same. As in the Policy Resolution, only rice mill has been excluded, we would hold that Chuda mill or any mill producing only Chuda would not be ineligible to get the incentives under the aforesaid Resolution. 4. In view of the above, we allow the petitions and state that the incentives made available by the Industrial Policy Resolution of 1986 would continue to be given to the petitioners for the required period. Of course, this decision of ours may not apply to those units which have been set up after issuance of Annexure-7. 5. The petitions are allowed accordingly. B.N. Dash, J. 6. I agree. Final Result : Allowed