Judgment ( 1. ) BY filing this writ under Articles 226 and 227 of the Constitution of India, the petitioner seeks quashing of an order rendered by the Commissioner of Sales Tax dated August 2, 2000, (annexure P10) under Section 68 of the M. P. Commercial Tax Act, 1994. Facts in so far as they are relevant for the disposal of the writ and which lie in a narrow compass need mention infra. ( 2. ) PETITIONER is a public limited company registered as such under the provisions of the Companies Act, 1956. It claims to be engaged in the business of manufacture of various drugs which according to the petitioner are basic drugs used in manufacture of other medicines. It has its manufacturing units at Mandideep in district Raisen. The petitioner is a registered dealer both under the State Sales Tax Act as also under the Central Sales Tax Act, 1956. ( 3. ) THE State Government in exercise of its powers conferred under Section 17 of the M. P. Commercial Tax Act, 1994 (for short called "the Act") has issued a Notification bearing No. A-3-32-97-ST-V- (22) dated May 9, 1997 exempting certain specified class of goods from payment of tax under the Act for the period (April 1, 1997 to March 31, 2000) to the extent specified therein. The notification reads as under : Notification No. A-3-32-97-ST-V-(22), dated May 9, 1997. Part I full exemption to certain items under Section 9 of Commercial Tax (State Act),- In exercise of the powers conferred by section 17 of the Madhya Pradesh Vanijyik Kar Adhiniyam, 1994 (No. 5 of 1995), the State Government hereby exempts the class of goods specified in column (2) of the Schedule below from payment of tax under the said Adhiniyam, for the period from 1st April, 1997 to 31st March, 2000, to the extent specified in column (3) of the said Schedule :-SCHEDULE S. No. Class of goods Extent of exemption (1) (2) (3) 1. Hearing aids Whole of tax under Section 9 2. Spectacles, the selling price Whole of tax under Section 9 of which do not exceed Rs. 200 per piece. 3. Basic drugs, when used as raw Partly so as to reduce the rate material for manufacture of of tax under Section 9 to 2 per medicines. cent. ( 4. Hearing aids Whole of tax under Section 9 2. Spectacles, the selling price Whole of tax under Section 9 of which do not exceed Rs. 200 per piece. 3. Basic drugs, when used as raw Partly so as to reduce the rate material for manufacture of of tax under Section 9 to 2 per medicines. cent. ( 4. ) CAPROLACTUM, Dimethy-Iterphthlate Partly so as to reduce the rate (DMT) and Monoethylene glycol (MEG) of tax under Section 9 to 1 per cent. ( 5. ) COMPUTERS Partly so as to reduce the rate of tax under Section 9 to 2 per cent. ( 6. ) MEDICAL equipments Partly so as to reduce the rate of tax under Section 9 to 2 per cent. 4. So far as the present petition is concerned, it relates to class of goods specified in serial number 3 in the aforementioned notification. It is, therefore, separately reproduced as under : SCHEDULE S. No. Class of goods Extent of exemption 3. Basic drugs, when used as raw Partly so as to reduce the rate material for manufacture of of tax under Section 9 to per medicines. cent. 5. According to the petitioner, they were entitled to payment of concessional rate of tax on the basic drugs manufactured by them as per aforementioned notification. Since, according to petitioner, the sales tax authorities instead of demanding concessional rate of tax, demanded usual rate of tax from the petitioner by sending a demand under the Central Sales Tax Act for the periods 1997-1998, 1998-1999 and 1999-2000 (annexure P5), the petitioner invoked the provisions of section 68 of the Act by making an application (annexure P6) to the Commissioner of Sales Tax and requested the learned authority to decide the question in respect of the rate of tax payable on the goods manufactured by the petitioner. The learned Commissioner by impugned order dated August 2, 2000 (annexure P10) disposed of the application made by the petitioner interpreting the entry (S. No. 3) contained in the notification. According to Commissioner the exemption notification is a conditional one, depending upon fulfilment of conditions specified therein. The petitioner not being satisfied with the interpretation made by the Commissioner has filed this writ and has sought its quashing. 6. The State by filing reply has supported the impugned order. ( 7. According to Commissioner the exemption notification is a conditional one, depending upon fulfilment of conditions specified therein. The petitioner not being satisfied with the interpretation made by the Commissioner has filed this writ and has sought its quashing. 6. The State by filing reply has supported the impugned order. ( 7. ) HEARD Shri A. M. Mathur, learned Senior Counsel with Shri S. S. Saraf, learned Counsel for the petitioner and Shri S. Mukati, learned Government Advocate for the respondents. ( 8. ) IN short and in substance, the question that falls for consideration in this writ is what is the true interpretation of entry No. 3 quoted supra, in the aforementioned exemption notification ? ( 9. ) SHRI Mathur, learned Senior Counsel appearing for the petitioner, argued that on proper interpretation of the relevant entry 3, the words "when used as raw material for manufacture of medicines" after the words "basic drugs" mentioned in the entry are superfluous or in any event redundant. According to learned Counsel, it is impracticable to ascertain whether a particular drug is being actually used or would be used for manufacturing some other drug by the purchaser of those drugs. Learned counsel urged that the exemption benefit is essentially to goods which are capable of being used for manufacturing other drugs and not on its actual use ultimately. In other words, the submission is that use of goods (drugs) in manufacture of other goods cannot be taken to be or/and should not be the basis for claiming the benefit/exemption contained in the notification. This in substance was the submission of learned Counsel for" the petitioner while assailing the view taken by the Commissioner on the interpretation of the relevant entry 3 of the notification. Learned counsel made reference to several authorities and the observations made therein to support his submissions. ( 10. ) IN reply, the submission of learned Counsel for the State was for dismissal of petition, and for upholding of the view taken by Commissioner in the impugned order. Learned counsel also contended that while interpreting the relevant entry 3 the interpretation suggested by learned Counsel for the petitioner is not borne out of the language employed in the entry. According to learned Counsel, the notification is a conditional one and hence its benefit can be granted only on fulfilment of the conditions, i. e. , qualifying words employed therein. ( 11. According to learned Counsel, the notification is a conditional one and hence its benefit can be granted only on fulfilment of the conditions, i. e. , qualifying words employed therein. ( 11. ) HAVING heard the learned Counsel for the parties and having perused the entire record, I find no merit in the submissions made by learned Counsel for the petitioner. ( 12. ) IN my opinion, careful reading of the words employed in entry 3 of the notification would leave no manner of doubt that it has no ambiguity in its construction as contended by learned Counsel for the petitioner. It being a settled principle of rules of interpretation that every word used in statute by the Legislature has its own importance and role to play in the construction of the sentence equally applies in this case too. When the Legislature has used the words "when used as raw material for manufacture of medicines" after the words "basic drugs", then it has to be given its logical and natural meaning. These words are in the form of qualifying words to the earlier words "basic drugs". In other words, the benefit of notification is available to a dealer only when the basic drugs to which benefit is given are used as a raw material for manufacture of other medicines. If those drugs are not used in manufacture of medicines then in that event the benefit of notification cannot be given. ( 13. ) IN effect, therefore, the grant of exemption/benefit is conditional one. The use of the words "when used as raw materials" is decisive in claiming the benefit on the basic drugs. The right to claim the benefit of exemption arises only on satisfying the authorities that a particular drug--say A or B is used as a raw material for manufacture of other medicines. In other words, if the dealer is able to satisfy the authorities that a particular drug is known in medical/ pharmaceuticals world as a basic drug and secondly it is always used for manufacture of other medicines as one of its raw materials then in my opinion, the dealer is entitled to get the benefit of exemption notification. ( 14. In other words, if the dealer is able to satisfy the authorities that a particular drug is known in medical/ pharmaceuticals world as a basic drug and secondly it is always used for manufacture of other medicines as one of its raw materials then in my opinion, the dealer is entitled to get the benefit of exemption notification. ( 14. ) LEARNED counsel for the petitioner also contended that there appears to be some lacuna or defect in the drafting of notification and secondly no such format is prescribed either by framing rules or clarification as to how and on what basis it will be proved that a particular drug is used or will be used in future by purchaser as raw material for manufacture of medicines. This submission has no force. If the State feels that in implementation of the notification some difficulty is being experienced it will take care of the infirmity by enacting either a rule or clarificatory notification. But such lacuna/defect expressed by learned Counsel is no ground to interpret the notification differently as suggested by the learned Counsel. ( 15. ) IN my opinion, it is for the dealer to satisfy the authorities that a particular drug satisfies the requirement of notification and hence is eligible to be taxed at a lesser rate of tax, i. e. , 2 per cent as against 9 per cent. It is then the authorities to decide on the basis of the material brought on record by the dealer whether to grant the benefit of lesser rate of tax on that particular drug on which the exemption is sought or not. In other words, it is then for the authorities to decide whether a case for claiming benefit in payment of lesser rate of tax on that particular drug is made out or not. ( 16. ) LEARNED counsel for the petitioner has cited several authorities in support of his submissions. These authorities are, [1968] 22 STC 152 (MP) (Commissioner of Sales Tax, Madhya Pradesh v. Kapoor Dori Niwar and Co.), 26 Cur. ( 16. ) LEARNED counsel for the petitioner has cited several authorities in support of his submissions. These authorities are, [1968] 22 STC 152 (MP) (Commissioner of Sales Tax, Madhya Pradesh v. Kapoor Dori Niwar and Co.), 26 Cur. T. J. 175 (MP), 1996 III AD (SC )483, AIR 1996 SC 1519 , JT 1996 (5) SC 549, 1996 (3) SCALE 11 , (1996) 8 SCC 84 , [1996] 3 SCR 678, [1996] 101 STC 529 (SC) [state of Uttar Pradesh v. Hindustan Safety Glass Works (P.) Ltd. ], JT 1994 (7) SC 206, 1994 (4) SCALE 711 , (1995) 1 SCC 58 , [1995] Supp5 SCR 123, [1995] 96 STC 355 (SC) (Commissioner of Sales Tax, Jammu and Kashmir v. Pine Chemicals Ltd.), [1987] 67 STC 427 (MP) (M. P. Shoe House v. State of M. P.) and W. P. No. 2744 of 1998, decided on December 8, 1998. ( 17. ) HAVING perused these authorities cited at the bar, I have not been able to find any of the authorities which will persuade me to accept the interpretation of an entry suggested by the learned Counsel. In the first place, the entry in question was not the subject-matter of interpretation in any of these authorities. In all these cases, a different entry fell for interpretation. In my considered opinion, I have to first interpret the words of the entry which are subject-matter of this petition in the context of its object and purpose. Aid can certainly be taken of the law explained in these authorities while interpreting the words that fell for consideration. In my view, the manner in which I have interpretated the entry in question gives full effect to the words employed therein and fulfil the objective for which it is enacted. To my mind, the object of the exemption notification is always to give benefit to a particular class of goods and on fulfilment of certain conditions. As in the present case, the benefit is not to a drug as such but it is available only when used as raw material for manufacturing some other medicine. Needless to observe, dismissal of petition would not be construed to mean that petitioner who is claiming the benefit of exemption notification would be denied the benefit even if they satisfy the conditions of the exemption notification observed by this Court. Needless to observe, dismissal of petition would not be construed to mean that petitioner who is claiming the benefit of exemption notification would be denied the benefit even if they satisfy the conditions of the exemption notification observed by this Court. In other words, if the petitioner proves to the satisfaction of authorities that they fulfil the conditions of the exemption notification, the authorities will have to grant them the benefit of notification. ( 18. ) IN view of aforesaid discussion, no case is made out to quash the order of Commissioner. Accordingly, I do not find any merit in the petition. It is dismissed. No costs.