Judgment :- RAJU, J. The above writ appeal has been filed against the Order of a learned Single Judge of this Court dated 27-8-1993 in W.P.No. 12490 of 1987 whereunder the learned Single Judge was pleased to quash the order of the Customs, Excise and Gold (Control) Appellate Tribunal, New Delhi, Special Bench-D, in Appeal No. E-1442/81-D - Order No. 168/1987-D and restored the order of the Central Board of Excise and Customs, New Delhi. 2.The short and relevant facts are that the first respondent/writ petitioner has produced a feature film under the title "Adavi Manushulu" in Telegu and that thereafter "Purana Purush" in Hindi, "Kattu Manidhan" in Tamil and "Silayugathil Sundarigal" in Malayalam were made based on the original Telegu film "Adavi Manushulu". From the order of the Tribunal below, it could be seen, while extracting paragraphs 13 and 14 of the Order of the Collector of Central Excise, Madras, as to what transpired in the preparation and making of the films and the method adopted in making such films. It appears that all the 55 prints in question of the feature film have been taken from one master negative, that since the story pertains to the pre-historic man of stone age, no language media or dialogue has been used and the entire communication is through various sounds, expressions and gestures and inasmuch as language media has been dispensed with totally in the main feature film, there was no occasion to change the sound track during the entire length of the film. But, at the same time, it is admitted that each language picture is in the form of an independent feature film with different title, different title piece, different censor certificate for films of different length and introductory speech in different languages pertaining to the particular language of the title adopted in each of the pictures. In such circumstances, the first respondent appears to have paid duty on 19 out of 55 prints and cleared the remaining without payment of duty availing of the benefit of the duty exemption granted by Notification No. 275/77, dated 12-8-1977. In such circumstances, the first respondent appears to have paid duty on 19 out of 55 prints and cleared the remaining without payment of duty availing of the benefit of the duty exemption granted by Notification No. 275/77, dated 12-8-1977. The Department felt that 55 prints so made since came out of a common negative, the first respondent was not entitled to the exemption and his availing of the same was mistake and error in law and consequently, issued a show cause notice dated 24-8-1978 calling upon the first respondent to pay the differential duty in a sum of Rs. 2, 07, 375/- and thereby confining the claim of exemption under the notification, noticed supra, to only 12 prints and demanding the differential duty in respect of 43 other prints. The first respondent opposed the claim of the Department. But, the Collector of Central Excise overruling the objections confirmed the proposals contained in the show cause notice. 3.Aggrieved, the first respondent moved the Central Board of Excise and Customs, New Delhi. The Board by its order dated 3-1-1981 accepted the reasoning of the first respondent and its claim for exemption, since it appears to the Board that language-wise, the film was different from the other not only in title but also in regard to the language in which the introductory portion of speech was covered and also for the further fact that separate censor certificates have been obtained for each of the language film and consequently allowed the appeal. Aggrieved, the Collector of Central Excise pursued the matter before the Customs, Excise and Gold (Control) Appellate Tribunal, New Delhi, which, by its order dated 3-3-1987, while upholding the claim of the Department, set aside the order of the Central Board and restored the Order of the Collector, Central Excise. The said order of the Tribunal came to be challenged by the first respondent herein in W.P.No. 12490 of 1987 seeking for the issue of a writ of certiorari to quash the order of the Tribunal. 4.The learned Single Judge was of the view that the reasons assigned by the Board to sustain the claim of the first respondent are sound in law and for no valid reasons, the same was interfered with by the Tribunal below. 4.The learned Single Judge was of the view that the reasons assigned by the Board to sustain the claim of the first respondent are sound in law and for no valid reasons, the same was interfered with by the Tribunal below. In coming to such a conclusion, the learned Single Judge adverted to some of the Acts in force, wherein the word "feature film" came to be defined, the peculiar facts and the manner in which the film has been made in different languages in the present case though to some extent, or so to say for substantial extents by copying from the main master copy negative, the further fact that the Tribunal has chosen not to properly express its view as to what it meant by "feature film" and observing further that the assumption of the Tribunal about some conventional manner of dubbing has no basis or justification, chose to come to the conclusion that even assuming that there is some area of doubts in the matter, being a question relating to enforcement of taxing statute, the same has to be liberally construed in favour of the citizen and allowed the writ petition by quashing the order of the Tribunal and directed restoration of the order of the Board sustaining the claim of the first respondent for exemption as availed of by it. 5.Mr. K. Jayachandran, learned Counsel for the appellant strenuously and with great force, contended that the order of the learned Single Judge does not conform to the very object and claim underlying the exemption notification, that since the language media has been dispensed with in the film and there is no change in the sound track and the picture remained same in all the 55 prints of the film, obviously made out of one negative, the order of the learned Single Judge cannot be sustained and that the mere fact that separate censor certificates have been obtained for each of the films made in different languages, is by itself no sufficient ground to construe each one of it as a separate feature film by itself to entitle its maker, the first respondent, eligible to avail of the minimum notified exemption upto first 12 prints in respect of each picture. 6.The relevant portion of the notification in question is as follows : "The Table" (Other portions omitted as unnecessary) 7.We have carefully considered the submissions of the learned Counsel appearing on behalf of the Department. In our view, the challenge made to the order of the learned Single Judge has no merit of acceptance. The Tribunal below, in our view, has not properly appreciated the scope of the notification or construed it in the manner it ought to have been done. As rightly pointed out by the learned Single Judge, the Tribunal appears to have proceeded upon certain assumptions based on typothetical considerations about the so called conventional methods of dubbing in considering the legality and propriety of the claim made by the first respondent. The Board, in our view, alone has approached the problem in its proper perspective when it observed that though the prints have been taken from the same master negative, language-wise each film is different from the other not only in title but also in regard to the language in which the introductory portion is covered. It may also be pointed out here that concedingly, the prints made in different language have their own title in the respective language with an introductory speech also in that part language before the main story of the feature film commenced. In that context, in our view, the absence of language, media or any dialogue in any portion of the main or story part of feature film has to go in favour of the particular language which precedes that portion or part of the film, where story part of the main feature film commence. Viewed thus, it has to be necessarily and inevitably viewed as a different feature film in different languages. The fact that the substantial portion of the feature film is silent or identical having relation to other films, will not make it anytheless different film in different language. It is in that context only, obtaining of separate censor certificates assumes significance and becomes vitally important in appreciating the claim of the first respondent and also testing the reasonableness, tanability and legality of the reasons assigned by the Board. It is in that context only, obtaining of separate censor certificates assumes significance and becomes vitally important in appreciating the claim of the first respondent and also testing the reasonableness, tanability and legality of the reasons assigned by the Board. As rightly pointed out by the learned Single Judge, the Cinematograph (Certification) Rules, 1983, made in exercise of the powers under the Cinematograph Act, 1952, Central Act, 37 of 1952, contains definition in a Section 2(ix) of "feature film" to mean fictional story film exceeding 2000 metres in length in 35 mm or corresponding length in other guages or on video. Rule 21 provides for making of application of examination of films and it contains an explanation that for the purpose of certification for public exhibition, every revised version or shorter version of a film shall be deemed to be a fresh film. 8.The law relating to the Cinematograph Act, which provides for certification of films, cannot be totally ignored as has been done by the Tribunal in this case in considering the claim for exemption, particularly having regard to the wordings of the exemption notification, which has been extracted supra. The entry, particularly the one relating to the description, makes it very clear that it has relevance to feature film not exceeding 4000 metres in length cleared for home consumption before the date of first release of the film for public exhibition. The censor Board cannot be taken to have issued separate certificates for the more asking unless specifically called for. Therefore, the relevancy of public exhibition, which renders, in our view, the principles incorporated in the Cinematograph Act being kept into consideration also for interpreting the scope of exemption notification, become very much relevant as also necessary. Consequently under the Cinematograph Act, separate certification for exhibition of the different films in different languages has been found to be necessary and has been as a matter of fact, also applied for and granted by the Central Film Censor Board. It is but necessary therefore, that they should be treated as different feature films and the fact that substantial portion of it was copies from out of the master negative, is no reason to reject the claim for exemption, unmindful of the difference in the length, different title for different languages and different introductory speeches in different languages in each one of those films. 9.For all the reasons stated above, we are in entire agreement with the reasons assigned by the learned Single Judge in arriving at the conclusion that the Tribunal below went wrong in disturbing the order of the Central Board for no sufficient reasons or grounds. Consequently, the writ appeal fails and shall stand dismissed. There will be no order as to costs.