Honble BALIA, J.–This revision is directed against the judgment dt. 24.9.98 passed by the Rajasthan Tax Board, Ajmer whereby the Tax Board, while allowing the appeal of M/s. Meera Stones Pvt. Ltd. for grant of `Eligibility Certificate under the Rajasthan Sales Tax Incentive Scheme 1987 as Diversification, has set aside the orders dt. 11.6.97 and 5.12.97 passed by the District Level Screening Committee. (2). The respondent-assessee has established an industrial unit for manufacturing of Mormo Tiles in 1988 at Chittorgarh and for which he was issued `Eligibility Certificate as new industrial unit under the aforesaid scheme. On 23.1.97 when the said Unit installed Marble Gangsaa and from which started production of Marbles Slabs also used as building material albeit for different purposes he made an application under Clause 2(g) of the scheme for grant of Eligibility Certificate on this diversification. Stating that he has spent more than 25% of the existing value of fixed assets of the original project. In the first instance the District Level Screening Committee rejected the application of the respondent-assessee by finding that it is not a diversification. The respondent-assessee again submitted application for reconsideration, the application again was rejected on 5.12.97 by finding that the unit is not in production at that time. Against the rejection of the application for grant of Eligibility Certificate as diversification the respondent-assessee preferred an appeal before the Rajasthan Tax Board which held establishing Gangsaa for production of Marble-Tiles in addition to existing production of Mormo-Tiles by the applicant amounts to diversification and finding that he otherwise fulfills condition of grant of Eligibility Certificate namely investment or more than 25% of the fixed capital of the existing project allowed the appeal and directed the D.L.S.C. to issue Eligibility Certificate within two months subject to verification of additional fixed capital investment requisite for quantifying eligibility to incentive as diversification. It is against this order of the Tax Board the Commercial Taxes Officer is now before this Court. (3). It is against this order of the Tax Board the Commercial Taxes Officer is now before this Court. (3). It has been urged by the learned counsel for the petitioner that definition of `Diversification means launching of new product line under the same company, firm or partnership and manufacture of Marble-Tiles cannot be said to be a `new product line but is engaged in the same product line in which the applicant is already engaged and therefore the Board was not right in accepting the case of the respondent to be a case of diversification and the D.L.S.C. in its first meeting held on 11.6.97 was right in rejecting the application for diversification. However, it is not disputed that in the event, the respondent may be eligible for exemption as expansion unit for which he was free to make a separate and independent application. (4). Mr. Kothari appearing for the respondent urged that new product line under Clause 2(g) must necessary mean not the same production of which installed capacity is to be increased under expansion but start of production of another commodities of the similar nature which are already being manufactured by the existing project. Manufacturing altogether new product unconnected with the existing project would make it to be case of new industrial unit for greater advantage under the scheme. (5). He places reliance on the decision of Gujrat High Court in Pranav Raj Paper Mills & Anr. vs. State of Gujrat (1). (6). The State Government is consistently framing incentive schemes in giving a impetus to investment in industrial growth of the State in its backward areas, subject to conditions and policy laid in the scheme as envisaged from time to time. Presently we are concerned with the Investment Scheme of 1987. It will be apposite to refer to the relevant features which have bearing on the present controversy. (7). The preface of the notification dt. 23.5.87 exempts industrial unit from payment of tax on the sales of goods manufactured by them in the manner and to the extent and for the purpose as covered by the notification. It will be apposite to refer to the relevant features which have bearing on the present controversy. (7). The preface of the notification dt. 23.5.87 exempts industrial unit from payment of tax on the sales of goods manufactured by them in the manner and to the extent and for the purpose as covered by the notification. Under Clause 2(a) of the scheme `New Industrial Unit has been defined to mean industrial unit which commences commercial production during the operative period of the Incentive Scheme but does not include (1) a new unit established by transferring or shifting or dismantling an existing industry; and (2) an industrial unit on the basis of the existing unit manufacturing similar goods. (8). `Expansion has been defined under Clause 2(f) to mean increase in the value of fixed capital investment by not less than 25% of the net fixed assets of the existing project accompanied with an increase of production to the extent of at least 25% of the original licenced/registered capacity. The benefits of Sales Tax Incentives for Expansion shall be admissible to the eligible units only after they have achieved at least 85% of their licenced/registered capacity before expansion. (9). `Diversification has been defined under Clause 2(g) to mean launching of new product line under the said company, firm or partnership provided that the total fixed capital investment in such a diversification exceeds at lest 25% of the value of the net fixed assets of the original project. (10). Computation of limit of quantum of Sales Tax Incentive that is permissible has been provided in the Annexure/C fixing percentage of ratio of the eligible fixed capital investment to be the limit of incentive enjoyable by the unit. Extent of maximum enjoyable limit for Expansion and Diversification in each category of industry is the same. For expansion and diversification fixed assets added that is new investment in fixed capital assets made for the purpose of making expansion or diversification are to be considered fixed capital investment for the purpose of quantifying the exemption under the scheme. In explanation appended to Annexure/C it has been clarified that in the case of expansion/diversification only the sales of the goods of expansion, production or diversification production as the case may be shall be entitled to incentive provided for. (11). In explanation appended to Annexure/C it has been clarified that in the case of expansion/diversification only the sales of the goods of expansion, production or diversification production as the case may be shall be entitled to incentive provided for. (11). If the three definitions `new industrial unit, `expansion and `diversification are considered together along with the preface of the notification it is abundantly clear that incentive is to the industrial units in respect of sales of goods manufactured by such units and is not to the person or goods in particular, nor to class of the person or goods of the particular category. Significantly the definition of `New Industrial Unit is wide enough to include any industrial unit which commences commercial production during operative period of incentive scheme. That is to say commencement of production by a industrial unit established de novo irrespective of its ownership is entitled to be treated as new industrial unit under clause 2(a). The only limits contemplated under the definition is where such industrial unit is established by transferring or shifting or dismantling an existing industry, it is not to be considered a new industrial unit meaning thereby more change in ownership or change of place of existing unit does not bring it to the category of new industrial unit so as to claim benefit of the new unit. So also where an industrial unit is established on the site of an existing unit manufacturing similar goods, it is not to be treated as new industrial unit. That implies bringing in existence an independent unit on different site falls in the category of a `New Industrial Unit distinct from Diversification or `Expansion in the context of scheme. So also bringing into existence an industrial unit at the same site also falls in the definition of a `New Industrial Unit when it is engaged altogether new goods which are not similar to goods already manufactured on the site. (12). One cannot also fail to notice that sub-clause (a) of clause 2 defining `new industrial unit has not used the expression `an existing unit manufacturing same goods. (12). One cannot also fail to notice that sub-clause (a) of clause 2 defining `new industrial unit has not used the expression `an existing unit manufacturing same goods. That is to say an existing unit if on the same site establishes a new unit manufacturing similar goods as are manufactured as existing unit it does not qualify for a being treated a New Industrial Unit notwithstanding that it may be that new and different product though similar to the goods produced at the existing unit at the very same site where the unit exists. It does not qualify for `Expansion also. Expansion means increase in the value of fixed capital investment over the existing fixed capital investment of existing project of which expansion is envisaged and is directly related to increase in the fixed capital investment by not less than 25% of the existing project and increase in the production of the original licence capacity by at least 25%. Explanation to Clause 2(f) further makes it a condition for claiming incentive benefits as an `Expansion that it should have achieved at least 85% of their licenced or registered capacity. Obviously then `Expansion can only relate to increase in the capacity of the existing unit to manufacture the same goods which it is producing in contrast to `similar products. This means on `Expansion being carried out it becomes integral part of the existing unit so that the increase in fixed capital investment as well as increase in capacity of production can be related to existing investment and production which makes the expansion as the integral part of the existing project. The entire gamut of `Expansion cannot be extended to starting manufacture of similar product but which is not the same product in the very nature of things else the entire definition becomes unworkeable. So far as increase in the installed capacity of production and achievement of the 85% of the licenced or registered capacity is concerned, it cannot be in respect of different products. (13). With this background when we read that `Diversification it has to be seen that firstly it is not linked with increase in installed capacity or licenced or registered capacity of original project because in the very nature of things the goods which is not the same, launching of such product by the existing unit cannot be linked with the existing project. But increase in the value of fixed capital investment is again linked with the fixed capital investment under the original project. Thus capital structure of diversification also becomes the integral part of the original project. One cannot fail to notice that while launching of a altogether new product even at the same site brings the same within the purview of `new industrial unit, of the same entrepreneur but to start a new production which can be considered to be different from but similar to product already being manufactured by the existing project on the same site, takes it out of definition `New Industrial Unit and it cannot also come within `Expansion as discussed above but can legitimately be treated as a `new product line under the same company, firm or partnership so as to fall within the purview of `Diversification. Expression `New Product line in the context of scheme and its object can only relate to new product which is not the same but different but similar to product already manufactured fall within the purview of `Diversification. Expression `New Product Line in the context of scheme and its object can only relate to a new product which is not the same but different yet similar to product already manufactured by the existing industrial unit or existing project. Any other view would lead to anomolous position namely installation of Industrial project manufacturing the same goods at different site by the same manufacturer in the same locality would neither be falling within the expansion nor Diversification but would be eligible for benefit as `New Industrial Unit inviting a higher incentive then establishing by a substantial new investment, a new product line of the similar goods already manufactured by the existing industrial unit. Such irrational construction has to be avoided unless the language of the statute is clear and it leads to no other conclusion. Explanation attached to Annexure/C restricts the advantage under the `Expansion or Diversification only to production referable to additional investment over investment in the existing project resulting in expansion viz. increased installed capacity of product already manufactured by it or in `Diversification resulting in manufacture of goods which is not the same already manufactured by it but the new investment in either case becomes integral part of capital structure of existing project. increased installed capacity of product already manufactured by it or in `Diversification resulting in manufacture of goods which is not the same already manufactured by it but the new investment in either case becomes integral part of capital structure of existing project. This lends support to the conclusion that in order to fall within the `Expansion or `Diversification under in incentive scheme, the same must become part of the existing project and that cannot happen without indulging in manufacture of the same goods or similar goods, else ordinarily it is not possible to make an industrial unit manufacturing altogether independent commodity to be integral part of the capital structure of the existing project. That falls within Clause 2(a) to qualify for incentive as `New Industrial Unit. (14). In this connection the decision of the Gujrat High Court in Pranav Raj Paper Mills case (supra), which was rendered in the context of the Sales Tax Incentive Scheme for Industries 1986 introduced by the Government of Gujrat under the Gujrat Sales Tax Act, 1969, which contain the similar provision and which in substance are not divergent from the scheme of the incentive scheme under the Rajasthan Sales Tax Act under consideration become relevant. A Division Bench of the Gujrat High Court taking into consideration of the definitions of `New Unit, `Expansion and `Diversification has concluded: ``A perusal of the definition goes to show that the expansion and diversification and the admissible exemption in the case of expansion and diversification has an integral link with the original project and they do not apply to independent industry. The expansion is considered to be one which increases in the value of fixed assets of capital investment by not less than 25% of the net fixed assets of the existing project coupled with an increase of production to the extent of at least 25% of the original installed capacity. This provision makes it abundantly clear that this applies to increase in the installed capacity of an existing unit and does not apply at all to come into existence of an altogether and independent new unit of the same product. Diversification has been defined to mean manufacturing of new pro-duct by specific manufacturer providing total fixed capital investment in such diversification exceeds at least 25% of the value of net fixed assets of original project. Diversification has been defined to mean manufacturing of new pro-duct by specific manufacturer providing total fixed capital investment in such diversification exceeds at least 25% of the value of net fixed assets of original project. Here also, if the linkage with the original project was not necessary the linkage with the 25% of the value of the fixed assets of the original project would have been redundant. (15). It may be noticed that in the above case the Court was considering where an existing unit for manufacture PVC goods and packing materials, had later on installed in adjoining land a unit for manufacturing paper. The unit had applied for exemption as the `new unit which though granted in first instance it was converted into `Diversification inter alia on the ground that starting of altogether new product was by the same entrepreneur was a case of `Diversification and not a case of `New Industrial Unit. The assessee has approached the High Court by way of the said Civil Special Application under Article 226. The court while coming to the aforesaid conclusion further observed that ``though in the definition of diversification the expression was launching of `New Product, under the consequential notification issued by the State Government, the expression launching of `New Product Line has been used. The Court expressed that launching of `New Product Line supports the conclusion which it has reached to co-relate the diversification is some way with the line of product of existing project or projects. It also stated that use of words `only additional manufacture of goods in Explanation (2) further goes to suggest that expansion and diversification should lead to additional value in the product of the original project either by way of increase in installed capacity or as a result of new product in the same line, or a new product which is alike to the product already manufactured. (16). As a result the decision of the Tax Board is upheld and it is held that launching of new product line in the context of diversification for the purpose of incentive scheme must relate to increase in fixed capital investment by 25%, as a result of which a new product in the same line or which is alike the same product already manufactured by the existing project, is manufactured by it. Establishing an industry for manufacturing altogether distinct product results in bringing into existence a `New Industrial Unit. (17). Accordingly this petition fails and is hereby dismissed. There shall be no order as to costs.