JUDGMENT A. K. MATHUR, C.J. - The petitioners by this petition have prayed that they should be subjected to purchase tax at the rate of 2 per cent instead of 3.5 per cent under section 7(2) of the M.P. General Sales Tax Act, 1958 (for short "the Act"). The petitioners have also prayed that the Notification No. A-3-19-1985(18)-ST-V dated 5th April, 1985 published in M. P. Rajpatra (Asadharan) No. 152 dated 6th April, 1985, pages 904 - 914 be amended in a manner that an equitable burden of taxation falls on the purchasing manufacturer who purchases entry tax paid good from others. 2. Brief facts giving rise to this petition are that the petitioners are carrying on the business of manufacture and sale of cables. They are dealers registered under the Act with the Sales Tax Officers of their respective circles at Jabalpur. They have been assessed to sales tax by the respondent No. 2, the Regional Assistant Commissioner of Sales Tax, Jabalpur. The petitioners are challenging the assessment orders passed by the respondent No. 2. The petitioner No. 1 was assessed for purchase tax for the period January 1, 1986 to December 31, 1986, petitioner No. 2 was assessed for the period from November 13, 1985 to November 1, 1986 and the petitioner No. 3 was assessed for the period from July 1, 1985 to June 30, 1986, by assessment orders passed by the respondent No. 2. The assessment orders are on record as annexures P1, P2 and P3. The matter was taken up in revision before the Additional Commissioner of Sales Tax, respondent No. 3, who upheld the assessment orders by orders dated June 14, 1991, on record as annexures P7, P8 and P9. The petitioners have therefore filed this petition challenging the validity of notification issued by the department granting certain exemptions under section 12 of the Act and also the assessment orders. 3. Section 7 of the Act provides for levy of purchase tax and under section 12 of the Act, certain exemptions have been given to the dealers of iron and steel that in case the goods purchased by them have suffered the entry tax from the selling dealer, then they will be charged sales tax at the concessional rate of 2 per cent instead of 3.5 per cent. The petitioners are challenging validity of notification annexure P10. The petitioners are challenging validity of notification annexure P10. For convenient disposal of this petition, it is proper to refer to the notification which is reproduced hereunder : "M.P. General Sales Tax Act, 1958 - Notification under section 12 - Reduced rate of tax on certain goods No. A-3-19-1985(18)-ST-V Bhopal, dated the 5th April, 1985. In exercise of the powers conferred by section 12 of the Madhya Pradesh General Sales Tax Act, 1958 (No. 2 of 1959), the State Government hereby exempts from 1st April, 1985 to 31st March, 1988 the class of goods specified in column (2) of the Schedule below from the payment of tax under section 6 and/or section 7, to the extent specified in column (3), and subject to the restrictions and conditions specified in column (4) of the said Schedule. SCHEDULE ------------------------------------------------------------------------ Sl. Class of goods Extent of Restrictions and conditions No. exemption subject to which exemption is granted. ------------------------------------------------------------------------ (1) (2) (3) (4) ------------------------------------------------------------------------ 77 (b) Iron and steel Partly so as When the goods are purchased as specified to reduce the by a registered dealer and in clause (iv) the rate of used as raw material in the of section 14 tax under manufacture of any goods of the Central section 7 to other than iron and steel as Sales Tax Act 2 per cent. referred to in column (2) 1956. and such finished goods are sold in the Madhya Pradesh or in the course of inter-State trade or commerce or in the course of export out of the territory of India and further that the goods referred goods referred to in column (2) had suffered entry tax under the Madhya Pradesh Sthaniya Kshetra Me Mal Ke Pravesh Par Kar Adhiniyam, 1976 (No. 52 of 1976) before they were purchased by such registered dealer." ------------------------------------------------------------------------ Principal submission of Shri Nema, learned counsel for the petitioners is that the last expression used in column (4) laying down restrictions and conditions subject to which exemption is granted is "before they were purchased by such registered dealer". Learned counsel submitted that in case the purchasing dealer purchases goods from selling dealer which has already suffered entry tax, then he is entitled to the concession of purchase tax at the rate of 2 per cent and in case the purchasing dealer himself effects the entry of the goods in a local area and suffers the incidence of entry tax then he is not given the benefit of this concession and he is charged purchase tax at the rate of 3.5 per cent. Learned counsel therefore submitted that this is discriminatory. In case the selling dealer pays the entry tax, concession is available to him; whereas the purchasing dealer himself purchases goods and pays entry tax, then he is not given exemption in view of aforesaid concessional notification. It is true that Entry Tax Act and the M.P. General Sales Tax Act are integrated systems of taxation in the State and the normal rate of tax in the present case, i.e., in regard to iron and steel is 3.5 per cent. But the concession has been given to those goods which have already suffered the entry tax at the hands of selling dealer and the purchasing dealer has to pay tax at the rate of 2 per cent only. Learned counsel for the petitioners submitted that it makes hardly any difference whether the selling dealer pays the entry tax or the purchasing dealer pays the tax. In either case, the goods suffer the entry tax and in both contingencies the purchasing dealer should be entitled to the benefit of the concession of tax at the rate of 2 per cent. Learned counsel submitted that in view of integrated nature of taxation, the maximum tax prescribed is 3.5 per cent only and if the purchasing dealer effects the entry of goods within a local area and suffers entry tax at the rate of 1.5 per cent, then he will have again to pay the purchase tax at the rate of 3.5 per cent. That will make the goods to suffer burden of tax at the rate of 5 per cent, which is not intended by the State Government. If that is what is intended, then a concession as has been given should not have been at all. That will make the goods to suffer burden of tax at the rate of 5 per cent, which is not intended by the State Government. If that is what is intended, then a concession as has been given should not have been at all. The argument of Shri Nema appears to be well founded that both the Acts are integrated tax laws in the State and the idea is that the goods should not suffer more than 3.5 per cent of tax. If the purchasing dealer pays tax, then no concession is given and that will increase tax up to 5 per cent. The fact remains that this is a tax exemption notification and the exemption notification has to be construed strictly. The courts cannot add or subtract from such notification. 4. Since the notification contemplates that concession will be given only in the event of selling dealer paying the entry tax - then and then alone the concession of 2 per cent will be available to the purchasing dealer and it is not vice versa that if the purchasing dealer brings the goods, then he will be entitled to the concession. The State in its wisdom has used the words very categorically laying down the restrictions and conditions subject to which such exemption is granted. In that case, this Court cannot substitute or subtract in the exemption notification in the manner Shri Nema, learned counsel wants to interpret. When the language used by the State is very clear and has no ambiguity in it, then the court has to give a meaning to it which it deserves, though we may strongly feel it otherwise but that makes no difference. We cannot amend the notification nor can we direct the State as to in what way it should grant a concession and what restrictions and conditions should be imposed. That is the privilege of the State. We can only point out the ambiguity as pointed out above that in case the purchases are made by purchasing dealer and he brings the goods within the local area and in case that goods has already suffered the entry tax, then it will be excess burden to such dealer because the concessional rate will not be available to him and he will be made to pay 5 per cent purchase tax. There will then be certainly excess burden on such purchasing dealer. There will then be certainly excess burden on such purchasing dealer. It is for the State to step in and correct this ambiguity. Now, we are told that in new Act, such ambiguity has been removed. Therefore, we are of the opinion that the notification cannot be struck down as being discriminatory by virtue of article 14 of the Constitution. In this connection, it would be relevant to mention here that their Lordships of the honourable Supreme Court have time and again emphasised that the concessional notification should be strictly construed. The reference may be made to a decision of the honourable Supreme Court in the case of Mac Laboratories (Pvt.) Ltd. v. Collector of Central Excise, Bombay (1995) 2 SCC 56 which is a case in which certain exemptions were given under the Central Excise Act. Their Lordships observed that the taxing statutes have to be strictly construed and specially the exemption notifications. It was also observed that if certain items fall in particular category, then concession should be given without any hesitation. Similarly, in the case of Novopan India Limited, Hyderabad v. Collector of Central Excise and Customs, Hyderabad (1994) Suppl 3 SCC 606 and in the case of Bombay Chemical Private Ltd. v. Collector of Central Excise, Bombay-I, Bombay (1995) Suppl 2 SCC 646 the same position was reiterated that the exemption notifications should be construed strictly. 6. In this view of the matter, though there is some scope for argument of ambiguity in the present notification (annexure P10) but nonetheless this Court cannot substitute or subtract the notification as it has to be construed in accordance with the terms and conditions laid down therein. We have also gone through the order passed by the Additional Commissioner in revision and from this also, we have not been able to understand whether the goods were purchased by the purchasing dealer after it had suffered the entry tax or not. From the order, it does not appear that such goods suffered entry tax. However, the learned counsel for the petitioners submit that the goods had suffered entry tax; but no such argument appears to have been advanced before the Additional Commissioner. Thus, we are not in a position to understand as to whether the goods had really suffered entry tax or not. However, the learned counsel for the petitioners submit that the goods had suffered entry tax; but no such argument appears to have been advanced before the Additional Commissioner. Thus, we are not in a position to understand as to whether the goods had really suffered entry tax or not. As per the order passed by the Additional Commissioner, it appears that the goods had not suffered entry tax and hence, the Additional Commissioner affirmed the orders of assessment officer. We therefore do not find any reason to interfere in the order passed by the Additional Commissioner. 7. In the result, we do not find any merit in the petition. It is accordingly dismissed. There shall be no orders as to cost. Security amount if any be refunded to the petitioners. Petition dismissed.