OM PRAKASH, J. This writ petition is filed by as many as six units, engaged in the manufacture of rice from paddy through their directors/partners for quashing the impugned notification dated May 21, 1994 (annexure "7" to the writ petition) issued by the State of U. P. (respondent No. 1 ). 2. The validity of the said notification was challenged earlier also before a Division Bench of this Court of which one of us (OM Prakash, J.) was a member in a bunch of writ petitions (Civil Misc. Writ Petition No. 645 of 1994 - Mentha & Allied Products v. State of U. P. [1996] 103 STC 316, being the leading case ). The Division Bench by an order dated January 17, 1996 [mentha & Allied Products v. State of U. P. [1996] 103 STC 316 (All.)] dismissed the entire bunch of writ petitions. 3. The petitioners in the said bunch of writ petitions challenged the validity of the impugned notification on the ground that so long as recognition certificates referring to full exemption granted to them remained in force, the liability of tax could not be altered and tax at the rate of two per cent could not be legally imposed on them by the impugned notification. The recognition certificates in that bunch of writ petitions were operative till the end of the year 1995-96 and, therefore, the petitioners pleaded that until the expiry of the year 1995-96, the petitioners could not be made liable to pay tax at the rate of two per cent. Then the court held that exemption or concession is not granted by a recognition certificate and that merely contains the conditions governing the exemption, but exemption, in fact, is granted by virtue of a notification issued by the State Government from time to time. Taking such a view, the contentions of the petitioners in the entire bunch of writ petitions were rejected and the impugned notification was held to be valid. 4. Sri M. G. Ramchandran, learned counsel for the instant petitioners, says that he wants to challenge the impugned notification wholly from a different angle and not on the ground commonly advanced on behalf of the petitioners in the aforesaid bunch of writ petitions earlier. 4. Sri M. G. Ramchandran, learned counsel for the instant petitioners, says that he wants to challenge the impugned notification wholly from a different angle and not on the ground commonly advanced on behalf of the petitioners in the aforesaid bunch of writ petitions earlier. This being so, learned counsel for the instant writ petitioners was permitted to argue, notwithstanding the objection of the respondents that the validity of the impugned notification has already been upheld by this Court by a judgment dated January 17, 1996 (Mentha & Allied Products v. State of U. P. [1996] 103 STC 316 ). 5. Section 4-B of the Uttar Pradesh Trade Tax Act, 1948 (briefly, "the Act") which was earlier named as the Uttar Pradesh Sales Tax Act, 1948, was inserted by the Uttar Pradesh Sales Tax (Amendment) Act, 1968. For the purposes of this case, sub-section (1), sub-section (2) and the Explanation to sub-section (2) are relevant. 6. Section 3-D (1) of the Act which is a charging section, provides for the levy on the turnover of first purchase. Section 4-B (1) (a) as inserted by the amending Act of 1968, in so far as relevant, says that where any goods liable to tax under section 3-D are purchased by a dealer who is liable to tax on the turnover of first purchase under that sub-section or where any goods are purchased by any dealer in circumstances in which such a dealer is liable to trade tax on purchases of such goods under section 3-AAAA and the dealer holds a recognition certificate issued under sub-section (2) in respect thereof, he shall be liable in respect of those goods to tax at such concessional rate or be wholly or partly exempt from tax whether unconditionally or subject to conditions and restrictions specified in that behalf, as may be notified in the gazette by the State Government in that behalf. 7. 7. Clause (b) to sub-section (1) of section 4-B provides that where any goods liable to tax under any other provision of this Act are sold by a dealer to another dealer and such other dealer furnishes to the selling dealer in prescribed form and manner a certificate to the effect that he holds a recognition certificate issued under sub-section (2) in respect thereof, the selling dealer shall be liable in respect of those goods to tax at such concessional rate, or be wholly or partly exempt from tax, whether unconditionally or subject to the conditions and restrictions specified in that behalf, as may be notified in the gazette by the State Government in that behalf. 8. Sub-section (2) of section 4-B provides that where a dealer requires any goods, referred to in sub-section (1), for use in the manufacture by him, in the State of any notified goods, or in the packing of such notified goods manufactured or processed by hhim, and such notified goods are intended to be sold by him in the State or in the course of inter State trade or commerce or in the course of export out of India, he may apply to the assessing authority in such form and manner and within such period as may be prescribed, for the grant of a recognition certificate in respect thereof, and if the applicant satisfies such requirements including requirement of depositing late fee and conditions as may be prescribed, the assessing authority shall grant to him in respect of such goods a recognition certificate in such form, and subject to such conditions, as may be prescribed. Whereas sub-section (1) of section 4-B refers to exemption, sub-section (2) of section 4-B refers to the grant of recognition certificate. Explanation to sub-section (2) which is also relevant, is reproduced below : " For the purposes of this sub-section, - (a) goods required for use in manufacture shall mean raw materials, processing materials, machinery, plant, equipment, consumable stores, spare parts, accessories, components, sub-assemblies, fuels or lubricants; and (b) notified goods means such goods as may, from time to time, be notified by the State Government in that behalf. " The impugned notification dated May 21, 1994 (annexure "7" to the writ petition) runs as follows : " In exercise of the powers under section 4-B of the Uttar Pradesh Trade Tax Act, 1948 (U. P. Act No. XV of 1948), read with section 21 of the Uttar Pradesh General Clauses Act, 1904 (U. P. Act No. 1 of 1904) and in supersession of all the previous notifications issued under the said section 4-B, the Governor is pleased to declare that with effect from June 1, 1994 and subjected to condition and restriction specified in the said section 4-B, the tax shall be payable at the rate of 2 per cent on the sale to or as the case may be purchase by, a dealer holding a valid recognition certificate under sub-section (2) of the said section 4-B, of any raw material, processing material, consumable stores, machinery, plant, equipment, spare parts, accessories, components, fuel or lubricants required by him for use in the manufacture of goods or of any goods required for use in the packing of goods manufactured by him : Provided that no concession under this notification shall be admissible in respect of sale to or purchase by distilleries and breweries. " 9. The submissions of Sri Ramchandran are as follows : (1) The heading of section 4-B, viz. , "special reliefs to certain manufacturers" implies that relief under section 4-B can be granted only to certain manufacturers and not generally to all manufactures. Section 4-B provides for a mandate that the State Government is required to select the goods first and then allow special reliefs to certain manufacturers and that mandate having not been carried out, the impugned notification is ultra vires of the provisions of the Act. (2) The intention behind the impugned notification was to rationalise the tax rate applicable to those falling under annexure III to the previous notification dated August 29, 1987. Annexure III provide for varying rates ranging between two to four per cent for varying goods which confused the dealers and consequently gave rise to a spate of litigation. The intention was, therefore, not to affect the goods/raw materials/manufactures falling under annexure I and but only those falling under annexure III to the notification dated August 29, 1987. Annexure III provide for varying rates ranging between two to four per cent for varying goods which confused the dealers and consequently gave rise to a spate of litigation. The intention was, therefore, not to affect the goods/raw materials/manufactures falling under annexure I and but only those falling under annexure III to the notification dated August 29, 1987. (3) The impugned notification classifies all manufacturers and all raw materials used in the manufacture of any goods into one class, notwithstanding the difference between them. Such classification being contrary to the objects of section 4-B and the scheme of the Act is arbitrary. (4) The words "notified goods" occurring in sub-section (2) of section 4-B are very significant and the requirement of the goods being notified is not a mere formality, but a condition precedent, but a condition precedent to give reliefs to those who hold recognition certificates under section 4-B. But for the requirement of notified goods, the provisions of section 4-B would have been unconstitutional being unguided, unchannelised and arbitrary. Notification of goods excludes arbitrariness and implies application of mind, as goods for the manufacture of which raw material is required by a dealer before being notified have to be selected by the State Government after application of mind. (5) Exemption under section 4-B is not to all manufacturers but to the manufacturers of the notified goods. The impugned notification is invalid, inasmuch as it does not notify the goods. (6) Radical change in section 4-B cannot be made by subordinate legislation and that is possible only through the amendment in the statute. To give relief to all the manufacturers on all the goods purchased by them for being used in the manufacture is beyond the scope of impugned notification and same is, therefore, ultra vires of section 4-B. (7) It is necessary that out of whole mass of goods and whole mass of manufacturers, certain goods and certain manufacturers should be selected. Any relief by way of concession or exemption - total or partial - may be given selectively, that is, in respect of the goods and manufacturers selected out of the whole mass of goods and manufacturers. (8) The impugned notification makes a departure from the past practice when the goods were duly notified and relief was given only to the manufacturers who purchased raw material required for use in the manufacture of the notified goods. 10. (8) The impugned notification makes a departure from the past practice when the goods were duly notified and relief was given only to the manufacturers who purchased raw material required for use in the manufacture of the notified goods. 10. Sub-section (2) of section 4-B clearly indicates that the goods for the manufacture of which raw material is required by a dealer, are required to be notified. Sri Ramchandran urges that without notifying the goods, relief under section 4-B is given to all manufacturers in respect of all the goods used by them in the manufacture by the impugned notification which is beyond the scope of section 4-B. 11. The question is what is the scope of section 4-B. Whereas the previous notification dated August 29, 1987 enumerated the goods and raw materials in annexures II and III, the impugned notification does not enumerate the notified goods or the raw materials required in the manufacture thereof. At flash, the submission of Sri Ramchandran that impugned notification is bereft of the basic ingredient of section 4-B appears to be attractive, but a deeper probe reveals that there is no substance in this argument. The Chief question for consideration is whether the power of the State Government to select the goods for giving relief as envisaged by section 4-B (1) (a) is restrictive. Section 4-B (1) (a) beginning with a non obstante clause, in so far as material, clearly states that where any goods liable to tax under sub-section (1) of section 3-D are purchased by a dealer who is liable to tax on the turnover of first purchase under that sub-section and the dealer holds a recognition certificate issued under sub-section (2) thereof, he shall be liable in respect of those goods to tax at such concessional rate or be wholly or partly exempt from tax whether unconditionally or subject to the conditions and restrictions specified in that behalf as may be notified in the gazette by the State Government in that behalf. The words "any goods" occurring in clause (a) are of great significance. They are not restrictive in nature; rather these words may take within their sweep either "one" or "some" or "all goods". A dealer holding a recognition certificate may be given relief in respect of any goods, liable to tax, meaning thereby, all goods required for use in the manufacture may be selected. They are not restrictive in nature; rather these words may take within their sweep either "one" or "some" or "all goods". A dealer holding a recognition certificate may be given relief in respect of any goods, liable to tax, meaning thereby, all goods required for use in the manufacture may be selected. When relief under clause (a) of section 4-B (1) can be given in respect of any goods, it logically follows that some or all goods can be correspondingly notified, as envisaged by section 4-B (2 ). The heading of section 4-B also does not indicate that the relief can be granted only to a few manufacturers. The words "certain manufacturers" occurring in the heading of section 4-B do not mean a few manufacturers. Certain manufacturers mean the manufacturers who are well ascertainable. Assuming that the words "certain manufacturers" mean a few manufacturers, we are of the view that the heading of section 4-B cannot be pressed into service, so long as the language of the section is clear, which in our view is so. The manufacturers may be ascertained either by naming all of them or by resorting to the process of elimination. The impugned notification eliminates sale to or purchase by distilleries and breweries. Excepting the sale to or purchase by distilleries and breweries, all other goods for the manufacture of which raw material is purchased by a dealer, stand notified and all purchases of raw material are subjected to uniform tax at the rate of two per cent. Simply because the impugned notification like the previous notification dated August 29, 1987, does not enumerate the goods for the manufacture of which raw material is purchased by a dealer, it cannot be said that goods have not been notified at all. Not the form but the pith and substance of the impugned notification is relevant. If the notification does not enumerate the goods, manufacturers of which are entitled to reliefs, it cannot be concluded that goods are not notified at all. From the language employed in the impugned notification, it can be deduced that the goods have been notified in residuary fashion in the following terms : " All other goods excepting the goods manufactured by distilleries and breweries. " Notifications have been made in residuary character in the past also. From the language employed in the impugned notification, it can be deduced that the goods have been notified in residuary fashion in the following terms : " All other goods excepting the goods manufactured by distilleries and breweries. " Notifications have been made in residuary character in the past also. Annexure III to the previous notification dated August 29, 1987 is an example, which runs as follows : ------------------------------------------------------------------------ " Sl. Names of Names of raw material, Rate of tax on No. notified goods etc. raw materials, etc.------------------------------------------------------------------------ 1 2 3 4 ------------------------------------------------------------------------ All other goods (1) Oil seeds 2 per cent (2) Oil-cake 3 per cent (3) Any other raw 4 per cent. " materials, accessories and component parts and packing materials.------------------------------------------------------------------------ 12. when the notification of residuary nature could have been and had been issued in the past, we see no good reason to invalidate the notification dated May 21, 1994, which also notifies all the goods in residuary fashion that is, excluding the goods manufactured by the distilleries and breweries. The only difference in the previous and the impugned notification is that the former was issued in respect of a few goods in so far as annexures I and II to that notification are concerned and the latter has been issued in regard to larger number of goods, that is, all the goods excepting the goods manufactured by distilleries and breweries. Entry at serial No. 3 of annexure II to the previous notification dated August 29, 1987 is material for the purposes of this case and that is reproduced below : Sl. No. 3 Rice Paddy Complete exemption was granted in respect of the purchases of paddy which is a raw material for the rice. By the impugned notification, raw materials required for use in the manufacture of al the goods which are notified in a residuary fashion, are subjected to a uniform rate of tax, that is, two per cent. 13. No. 3 Rice Paddy Complete exemption was granted in respect of the purchases of paddy which is a raw material for the rice. By the impugned notification, raw materials required for use in the manufacture of al the goods which are notified in a residuary fashion, are subjected to a uniform rate of tax, that is, two per cent. 13. Sri Ramchandran does not argue before us that the impugned notification is bad because it does not enumerate the raw materials required for use in the manufacture of the goods but his submission is that the impugned notification is bad in law, because the goods for the manufacture of which raw material is required by a dealer, have not been notified and that a vague and omnibus notification has been issued without specifying the goods, the manufacturers of which may be entitled to a relief on the raw materials. 14. The submission of Sri Rakesh Dwivedi, learned Additional Advocate-General is that the impugned notification came to be issued to rationalise the scheme underlying section 4-B and to obviate the litigation, incidence of which had gone high in the past. It is submitted that the dealers were not in a position to know precisely as to which rate was applicable to their cases and, therefore, the State Government thought it proper to rationalise the scheme underlying section 4-B as a whole. It is urged by him that except the goods manufactured by the distilleries and breweries and the raw materials needed by them, all other goods for the manufacture of which raw material is required by a dealer, stood notified by the impugned notification. Since it is cumbersome and difficult exercise to name all the goods for the manufacture of which raw material is required by a dealer, urges Sri Dwivedi, the State Government thought it fit to issue the impugned notification using the words : ". . . . . . . . . the tax shall be payable at the rate of 2 per cent on the sale to or as the case may be purchase by a dealer holding a valid recognition certification under sub-section (2) of said section 4-B of any raw material. . . . . . . . required by him for use in the manufacture of goods or of any goods required for use in the packing of goods manufactured by him". . . . . . . . required by him for use in the manufacture of goods or of any goods required for use in the packing of goods manufactured by him". Since the manufacturers applying the process of elimination, that is excluding the distilleries and breweries are well identifiable and ascertainable, we see a good reason to accept the submission of Sri Dwivedi that the impugned notification is intra vires of the provisions of section 4-B. When section 4-B confers a wide power to exempt any goods required for use in the manufacture of notified goods, the State Government is free to notify either some or all the goods to give relief to the manufacturers thereof. 15. It cannot be said that the impugned notification has been issued without application of mind. The proviso to the impugned notification which excludes sale to or purchase by distilleries and breweries, clearly indicates the application of mind on the part of the State Government. 16. Relying on the case of Indian Express Newspapers (Bombay) Pvt. Ltd. v. Union of India AIR 1986 SC 515, Sri Ramchandran submits that the impugned notification deserves to be quashed being unreasonable in the same way as an unreasonable or arbitrary administrative order is quashed by the court. The facts of the case of the Indian Express Newspapers (Bombay) Pvt. Ltd. AIR 1986 SC 515, are quite distinguishable and therefore, we are of the view that the same has been misplaced by Sri Ramchandran before us. In that case the petitioners engaged in the business of printing, editing and publishing newspapers, periodicals and magazines, etc. , contended that the imposition of import duty has the direct effect of the crippling the freedom of speech and expression guaranteed by the Constitution as it has led to the increase in the price of newspapers and the inevitable consequence of reduction of their circulation. The court was of the view that the respondent failed to consider the relevant material and taking the note of the fact that the notification withdrawing the complete exemption would affect the fundamental right of the petitioners, directed the authorities to re-examine the whole issue taking into consideration the relevant materials. No such fundamental right can be claimed in respect of paddy in which business transactions are held by the petitioners like other ordinary commercial transactions. No such fundamental right can be claimed in respect of paddy in which business transactions are held by the petitioners like other ordinary commercial transactions. Therefore, no aid can be taken by the petitioners from the case of Indian Express Newspapers AIR 1986 SC 515. 17. Then the question is whether the impugned notification is tainted with unreasonableness. Simply because the petitioners carrying on the business of manufacture of rice from paddy were fully exempt from tax under the previous notification dated August 29, 1987, levy of tax at the rate of two per cent on purchases of paddy by the impugned notification cannot be said to be unreasonable. Some of the manufacturers falling under annexure III to the previous notification dated August 29, 1987, are liable to pay tax at the rate of four per cent and they are benefited by the impugned notification to the extent of two per cent in tax rate. In so far as, the petitioners are concerned, the impugned notification has created a new liability of tax at the rate of two per cent, the other class of dealers as aforementioned is at the same time benefited by the impugned notification. The impugned notification cannot be said to be unreasonable simply because it create a liability for these who were covered by annexures I and II of the previous notification. In the matter of taxation which are full of complexities, a wide latitude has been given to the Legislature and so also to the authorities who are vested with the powers of subordinate legislation. 18. The contention of Sri Ramchandran that the impugned notification affects only falling under annexure III to the previous notification dated August 29, 1987, that is, a residuary class of manufacturers - does not commend us to be accepted. The impugned notification clearly supersedes the previous notification dated August 19, 1987 and there is nothing to indicate that the previous notification was superseded only partly, in so far as that relates to annexures III. The previous notification as a whole has been superseded by the impugned notification. The impugned notification clearly supersedes the previous notification dated August 19, 1987 and there is nothing to indicate that the previous notification was superseded only partly, in so far as that relates to annexures III. The previous notification as a whole has been superseded by the impugned notification. The representations made by those falling under annexure III of the previous notification dated August 29, 1987 regarding rationalisation of the tax structure, may be the starting point which moved the respondents to take up the task of rationalisation, but that does not mean that the impugned notification is confined only to those falling under annexure III to the previous notification. 19. Exemption cannot be claimed by any one as matter of right. Exemption implies that the goods are taxable. Exemption can be claimed only when it is granted. No one can as a matter of right ask for exemption. Simply because paddy was exempt under the previous notification dated August 19, 1987, the petitioners could have no grievance if exemption is completely withdrawn or purchases of paddy are subjected to tax. So long as the power to grant exemption is exercised within the scope of section 4-B, which we think it was so exercised, challenge to the impugned notification cannot be sustained. 20. In the past, the goods required for use in the manufacture of notified goods by a manufacturer, were either fully exempt or were subjected to tax at varying rates. To obviate fiscal complications and to rationalise and simplify the tax structure, the State Government thought it fit to issue the impugned notification to bring about uniformly in the tax rate. The uniform tax rate removes the distinction and such a step, unless the fact-situation warrants otherwise is always consistent to article 14 of the Constitution and that cannot be branded arbitrary in any way. 21. Lastly, we fail to understand the wisdom of the petitioners in filing this writ petition. If the impugned notification is quashed as prayed then the previous notification dated August 29, 1987 having been fully superseded, the petitioners will be burdened with greater liability of tax. Sri Ramchandran urges that if the intention is to confer some benefit and if the notification turns out to be bad then the earlier notification will stand revived. If the impugned notification is quashed as prayed then the previous notification dated August 29, 1987 having been fully superseded, the petitioners will be burdened with greater liability of tax. Sri Ramchandran urges that if the intention is to confer some benefit and if the notification turns out to be bad then the earlier notification will stand revived. It is submitted by him that by the impugned notification, tax liability is imposed at a concessional take of two per cent and, therefore, if the impugned notification is quashed then the previous notification will stand revived. We see no force in the submission. The matter may be looked at from another angle also. Under the previous notification tax liability was nil in so far as the petitioners are concerned and by the impugned notification a new tax liability has been created and, therefore this is not a case where intention was to confer some benefit on the petitioners, but the intention was to create a new liability by rationalising the tax structure. In the Indian Express Newspapers case AIR 1986 SC 515, this question came up before the Supreme Court and then the court held that the old notification giving exemption on the purchase of newsprint could not revive on the quashing of the impugned notification. For the reasons, we decline to accept the submissions of Sri Ramchandran and reiterate that the impugned notification is valid. The petition, therefore, fails and is dismissed. However, the parties will bear their own costs. Petition dismissed. .