JUDGMENT T. L. VISWANATHA IYER, J. - The finding of fact entered by the Tribunal is that the soap dealt with by the assessee was manufactured by a unit recognised by the Khadi and Village Industries Commission constituted under the Khadi and Village Industries Commission Act, 1956 and as such it was entitled to the exemption under S.R.O. No. 287/64. The contention of the learned Government Pleader is that the exemption is available only if the goods are also sold by an institution which is recognised by the Khadi and Village Industries Commission. There is no warrant for this submission in the notification. Under the notification the exemption is available for "products of village industries where such goods are manufactured and/or sold by the institutions of (sic) persons recognised by the Khadi and Village Industries Commission constituted under the Khadi and Village Industries Commission Act, 1956 (Central Act 61 of 1956) and/or the Kerala Khadi and Village Industries Board constituted under the Kerala Khadi and village Industries Act, 1957 (Kerala Act 9 of 1957)". Three categories of goods are comprehended by the notification, namely, those manufactured by such an institution, those sold by them and those manufactured and sold by them. That is the effect of the words "and/or", though it does lead to a certain amount of overlapping. Acceptance of the contention of the learned Government Pleader will mean that we have to read the words "manufactured and/or sold" as "manufactured and sold". It is not possible for this Court to redraft the notification to read it in the manner in which the learned Government Pleader wants it. We have to interpret the notification as it stands in which event it is enough if the goods are either manufactured or sold by an institution recognised by the Khadi and Village Industries Commission, to entitle it to be exemption. In view of the finding definitely entered by the Appellate Tribunal that the institution which manufactured the soap in question was one recognised by the Khadi and Village Industries Commission, there can be no doubt that the goods are eligible for exemption under the notification in question. 2. The Government Pleader faintly argued that the recognition of the institution was only for the year ending March 31, 1984 and that it did not ensure for the year with which we are concerned, namely, 1984-85 and 1985-86. 2. The Government Pleader faintly argued that the recognition of the institution was only for the year ending March 31, 1984 and that it did not ensure for the year with which we are concerned, namely, 1984-85 and 1985-86. Such a contention was not raised before any of the authorities below, not again in these revision cases. The point raised is essentially one of fact, which, if true, should have been raised before the authorities. We are not therefore inclined to entertain this plea made for the first time before us at the stage of arguments. The tax revision cases therefore fail. They are dismissed accordingly. Petitions dismissed.