JUDGMENT G. SIVARAJAN, J. – All the writ appeals are filed by dealers in arecanut, who are also assessees to sales tax under the Kerala General Sales Tax Act, 1963 (for short, "the Act"). The appellant in M.F.A. No. 142 of 2002 is an association of arecanut dealers at Kokkala in Thrissur District, in which the appellants in the writ appeals are members. The main question arising for consideration in all these cases relates to the scope and content of the last part of the notification, S.R.O. No. 127 of 2000. The relevant portion reads : "This notification shall be deemed to have come into force on the first day of January, 2000. Tax, if any, already collected in the higher rate shall be paid over to Government and tax, if any, already paid shall not be refunded." In the case of the appellants in the writ appeals, the assessing authority under the Kerala General Sales Tax Act, 1963 (for short, "the Act") had originally understood the above clause as one providing for non-refund of the tax already paid only in the case of tax collected and paid, and accordingly, in the case of the said appellants, whose liability to pay tax on the turnover of purchase of arecanut was at the last purchase point, and whose liability to pay tax does not depend upon collection of tax on that point, the tax paid by them were ordered to be refunded. But instead of making refund, the same was ordered to be adjusted towards the pending demands or future demands. Later, the assessing authority, however, has taken the view that the refund was ordered by mistake, and issued notice under section 43 of the Act for correcting the said mistake. It is at that point of time the association of the appellants took up the matter before the Commissioner of Commercial Taxes, by filing an application, annexure A-II to M.F.A. No. 142 of 2002, seeking clarification regarding the scope of the clause, which we have already extracted above. By this time, one of the appellants, viz., appellant in W.A. No. 169 of 2003 filed O.P. No. 17247 of 2001 challenging the notice issued under section 43 of the Act. By this time, one of the appellants, viz., appellant in W.A. No. 169 of 2003 filed O.P. No. 17247 of 2001 challenging the notice issued under section 43 of the Act. The Commissioner of Commercial Taxes considered the application, annexure A-II, submitted by the association, which is the appellant in M.F.A. No. 142 of 2002 and had issued annexure A-III order, clarifying that the dealers, who have paid tax on the purchase turnover of arecanut at the rate of eight per cent for the period from January 1, 2000 to February 5, 2000, would not be eligible for any refund of the tax already paid. This order of the Commissioner of Commercial Taxes is the subject-matter of M.F.A. No. 142 of 2002. The appellants in the writ appeals have also challenged this order in their writ petitions, from which the present writ appeals arise. Of course, there is also a challenge in the writ appeals against the notices under section 43 issued by the authorities for rectifying the mistake as pointed out earlier. From the above facts it is clear that the main issue that arises in all these cases is regarding the scope of the last paragraph of the notification, S.R.O. No. 127 of 2000, which we have extracted in paragraph No. 1 above. Before proceeding to consider the scope of the said clause, it is necessary to refer to some factual details as well as the position regarding the liability to pay tax on arecanut. According to the appellants in the writ appeals, all of them are doing business in arecanut in Kokkala market at Thrissur. It is also their case that they are acting as agents of non-resident principals. It is stated that the nature of business dealt with by the dealers in arecanut has been judicially recognised by a Full Bench of this court in A. I. Manie v. State of Kerala [1963] 14 STC 657. It is not necessary for us to elaborate much on the nature of the business considered in the above case for the purpose of this case, and therefore, we are not elaborating. It is not necessary for us to elaborate much on the nature of the business considered in the above case for the purpose of this case, and therefore, we are not elaborating. The factual details, which are necessary for the purpose of this case, are briefly as follows : The appellants in the writ appeals, who are the members of the appellant - association in M.F.A. No. 142 of 2002, purchase arecanut locally from growers who bring the same to the shop of the appellants. The appellants, thereafter, despatch the same to their non-resident principals outside the State. Arecanut is taxable under entry 7 of the First Schedule at two stages, though the levy is a single point levy. So far as local purchase of arecanut is concerned, it is taxable at the last point of purchase by a dealer liable to tax under section 5(1) of the Act. Whereas in so far as arecanut, which is imported from outside the State is concerned, it is liable to tax at the point of first sale in the State by a dealer, who is liable to tax under section 5(1) of the Act. According to the appellants, all of them are dealing only with local purchase of arecanut from growers, and therefore, the turnover of arecanut purchased by them is taxable only at the point of last purchase inside the State. It acquires the quality of last purchase as soon as the goods are despatched to outside the State principals, by virtue of section 8 of the Act. As such, as soon as the appellants despatch the goods purchased from the growers inside the State to outside the State principal, the liability to pay tax fastens on them. It is the case of the appellants that they have remitted the tax due on the purchase turnover of arecanut since the said turnover acquired the quality of last purchase before the issuance of the notification S.R.O. No. 127 of 2000 with retrospective effect from January 1, 2000. Here, it must be noted that the rate of tax of arecanut up to December 31, 1999 was five per cent and from January 1, 2000 onwards the rate of tax was enhanced to eight per cent. Here, it must be noted that the rate of tax of arecanut up to December 31, 1999 was five per cent and from January 1, 2000 onwards the rate of tax was enhanced to eight per cent. While the matter stood thus, the Government, in public interest, issued the Notification, S.R.O. No. 127 of 2000 dated February 5, 2000, reducing the rate of tax on arecanut from eight per cent to four per cent. This notification was given retrospective effect from January 1, 2000. However, this retrospective effect was subject to the conditions contained in the last paragraph of the notification, which we have already extracted in paragraph 1 above. Before considering the scope of the said clause, it is also relevant to note that under the provisions of the Kerala General Sales Tax Act it is not an incidence of taxation that the sales tax must be passed on to the purchaser. It is well-settled that the liability to pay sales tax arises as soon as the sale of a commodity is effected, irrespective of the fact whether sales tax has been charged in the bill separately or not. The selling dealer is liable to pay tax, in case the taxable event is the sale on the taxable turnover computed in accordance with the provisions of the Act, provided the total turnover of such dealer is not below the limit prescribed under section 5(1). Of course, section 22 of the Act clearly provides for passing on the tax liability on the purchaser. It is also noteworthy that in respect of the liability to pay sales tax on the purchase, i.e., at the point of last purchase, there is no question of collecting any tax from any dealer. All these we have stated only to show that the collection of sales tax is not an incident of tax for the purpose of levy of sales tax. A dealer is liable to pay tax on the taxable turnover, even if he has not collected sales tax. If such a dealer, by virtue of his liability, had remitted the tax due on his turnover, he cannot have any grievance that the payment was illegal, nor can he demand that the tax already paid in accordance with law must be refunded. If such a dealer, by virtue of his liability, had remitted the tax due on his turnover, he cannot have any grievance that the payment was illegal, nor can he demand that the tax already paid in accordance with law must be refunded. The same is the position of a dealer, who, by virtue of the provisions of the Act, is liable to pay tax on his turnover of purchase without the facility for collection of tax from the customers. If such a dealer pays tax to the State in accordance with law, he cannot also have any complaint against such payments, nor can he demand refund of the said amount from the Government. Now we will consider the scope of the last paragraph of the notification, S.R.O. No. 127 of 2000, which we have already extracted. This clause gives retrospective effect to the notification dated February 7, 2000, with effect from January 1, 2000. However, as already noted, this is expressly made subject to (i) tax, if any, already collected in the higher rate shall be paid over to the Government and (ii) tax, if any, already paid shall not be refunded. It is the contention of the appellant that these two clauses have to be read conjunctively and not disjunctively. It is stated that the collection of tax is a necessary ingredient for the application of the two clauses mentioned above. In other words, what the notification says is that if the dealer has collected tax at the higher rate, and kept in his possession, it must be paid over to the Government, and if the tax collected has already been paid over to the Government, the same will not be refunded. In short, the contention of the appellants is that the intention of the Government in providing such a condition is that the dealers should not be allowed to enrich themselves by the benefit granted under the notification. The appellants also contend that in the case of dealers like the appellants, there is no question of collection of sales tax by them for the reason that the liability to tax on arecanut is only at the point of last purchase in the State, and consequently, the liability to pay tax is on the purchasing dealer and not to the selling dealer. As such, there is no question of collection of sales tax from anybody. As such, there is no question of collection of sales tax from anybody. It is also their case that if the clause is understood disjunctively and if the intention of the notification is understood to be one for general application, viz., irrespective of collection of tax, if tax has already been paid, the same will not be refunded, a situation may arise, where an honest dealer remits the tax due on his purchase turnover in time and a dishonest dealer or a dealer, for other reasons, does not file the return accompanied by payment of the tax due thereon, if the clause in the notification is understood as applicable to a bona fide dealer, who had only paid the tax in time, that will amount to a premium being given to the dishonest dealer, and further, that will tantamount to discrimination, which attracts the provisions of article 14 of the Constitution. On the other hand, the contention raised by the respondent is that the intention of the Government in imposing such a condition was that by granting retrospective operation, Government should not be put in a situation where they have to refund the amount already received and appropriated towards the budgetary needs. It is also the case of the respondent that in a case where the taxable event, so far as arecanut is concerned, is made at two different stages, that is, in so far as local purchase of arecanut is concerned at the point of last purchase and in so far as arecanut imported from outside the State is concerned at the point of first sale in the State, if the collection of tax is made a condition precedent for the applicability of both the clauses mentioned above, that will amount to discrimination between the two classes of dealers, who are dealing with the same item. The Government Pleader further submitted that the clause is very clear in that it clearly provides that tax, if any already paid, shall not be refunded. If the tax has already been paid, then the notification clearly says that it will not be refunded. He submitted that when the notification is very clear and unambiguous, there is no question of importing any other meaning to what has been provided in the notification. If the tax has already been paid, then the notification clearly says that it will not be refunded. He submitted that when the notification is very clear and unambiguous, there is no question of importing any other meaning to what has been provided in the notification. Counsel also relied on the decision of the Supreme Court in State of Kerala v. Vattukalam Chemicals Industries [2001] 124 STC 233; [2002] 10 KTR 69. We have already narrated the background, both factual and legal, so far as the liability to tax on arecanut is concerned. As already noted, it is not an incident for the liability to tax that the tax should be collected by a dealer. The scheme of the Act, as could be seen from the First Schedule, itself makes the position clear. In respect of goods which are taxable at the point of first sale in the State by a dealer liable to tax under section 5 by virtue of the provision of section 22 of the Act, such dealer can collect tax on his sale. Whether the dealer collects tax or not, he has to pay tax on his taxable turnover as provided in rule 21(7) of the Kerala General Sales Tax Rules, 1963 (for short, "the Rules"). In the case of a dealer, whose transaction, as in the present case, is liable to tax only at the last point of purchase, there is no question of collection of tax by that dealer from anybody on that point. In spite of that he has to pay tax on his taxable turnover. So, the collection of tax is not relevant, so far as the liability is concerned. Say, for example, if a dealer, who is liable to pay tax at the point of first sale in the State of Kerala, without collection of tax from the purchasing dealer pays tax on his turnover as provided under the statute, can such a person claim that by virtue of the retrospective amendment he is also entitled to refund of the tax already paid. If such a person cannot claim refund, it follows that a dealer, who is liable to pay tax on his turnover at the point of last purchase in the State and had paid the tax promptly, is in the same position as in the case of the dealer mentioned above. If such a person cannot claim refund, it follows that a dealer, who is liable to pay tax on his turnover at the point of last purchase in the State and had paid the tax promptly, is in the same position as in the case of the dealer mentioned above. The decision of the Division Bench of this court in Assistant Secretary of Sales Tax (Law), Board of Revenue (Taxes), Ernakulam v. Jimmy Antony [1998] 108 STC 401 is of no assistance to the appellant. Though a similar provision as in the clause with which we are concerned came up for consideration in that case also in the context of the notification S.R.O. No. 968 of 1980, the issue in that case was totally different, viz., whether the tax collected and remitted to the Government during the pendency of the application for eligibility certificate has to be ignored and the tax liability determined has to be adjusted from the amount of exemption specified under the eligibility certificate specified under the notification. In that context the Division Bench observed as follows : "The exemption available to the unit under the notification is subject to two riders, namely tax, if any, collected by the unit has to be paid over to the Government and tax, if any, already paid by the unit to the Government shall not be refunded. These riders only show that the assessee may, during the pendency of the application for exemption, bona fide collect tax on the turnover of sale of goods produced by them providing for a contingency and in such cases they should not be allowed to take advantage of the amount by appropriating the same and claim exemption in respect of that turnover. There is nothing in the notification, according to us, to show that such an assessee who had bona fide collected and remitted tax on the turnover of sale of goods produced and sold by them during the period during which they were entitled to exemption could lose the benefit of the exemption notification to that extent. According to us, such assessees can claim the benefit of the full amount of exemption available as per the eligibility certificate for the remaining period notified in the eligibility certificate if they have not collected any tax on the turnover of sale of goods produced by them during the said period. According to us, such assessees can claim the benefit of the full amount of exemption available as per the eligibility certificate for the remaining period notified in the eligibility certificate if they have not collected any tax on the turnover of sale of goods produced by them during the said period. ..." The Division Bench did not go into the scope of the rider to the notification considered above. So, nothing turns on the said decision. According to us, the notification is very clear that it clearly provides that if the dealer has already paid tax, it shall not be refunded. Admittedly the appellants have paid tax on their purchase turnover, at the time of issuance of the notification, and therefore, in view of this clause, they are not entitled to get refund of the excess tax paid. It is a well-recognised canon in the interpretation of statutes that the question of interpretation of statute, rule or notification arises only when the statutory provision is ambiguous. As already held by the Supreme Court in Vattukalam Chemicals Industries' case [2001] 124 STC 233; [2002] 10 KTR 69, when the language of the notification is crystal clear, no external aid to its construction is required. The Act in question is a taxing statute and, therefore, must be interpreted as it reads, with no additions and no subtractions, on the ground of legislative intendment or otherwise (V.V.S. Sugars v. Government of Andhra Pradesh [1999] 114 STC 47 (SC); [1999] 4 SCC 192). It is also well-settled principle that while construing revenue Acts courts have to give a fair and reasonable construction to the language of the statute without leaning to one side or the other, meaning thereby that no tax or levy can be imposed on a subject by an Act of Parliament without the words of the statute clearly showing an intention to lay the burden on the subject. In this process, the courts must adhere to the words of the statute and the so-called equitable construction of those words of the statute is not permissible. In this process, the courts must adhere to the words of the statute and the so-called equitable construction of those words of the statute is not permissible. The task of the court is to construe the provisions of taxing enactments according to the ordinary and natural meaning of the language used and then to apply that meaning to the facts of the case and in that process if the tax-payer is brought within the net he is caught, otherwise he has to go free [Vikrant Tyres Ltd. v. First Income-tax Officer, Mysore [2002] 127 STC 5 (SC)]. Again this principle is reiterated by the Supreme Court in Federation of Andhra Pradesh Chambers of Commerce and Industry v. State of Andhra Pradesh [2000] JT 8 SC 516; AIR 2000 SC 2905 as follows : "It is trite law that a taxing statute has to be strictly construed and nothing can be read into it. In the classic passage from Cape Brandy Syndicate [1921] 1 KB 64, which was noticed in the judgment under appeal, it was said : 'In a taxing Act one has to look merely at what is clearly said. There is no room for any intendment. There is no equity about a tax. There is no presumption as to a tax. Nothing is to be read in, nothing is to be implied. One can look fairly at the language used.' This view has been reiterated by this court time and again. Thus, in State of Bombay v. Automobile and Agricultural Industries Corporation, Bombay [1961] 12 STC 122 (SC), this court said : 'But the courts in interpreting a taxing statute will not be justified in adding words thereto so as to make out some presumed object of the Legislature. ... If the Legislature has failed to clarify its meaning by the use of appropriate language, the benefit thereof must go to the tax-payer. It is settled law that in case of doubt, that interpretation of a taxing statute which is beneficial to the tax-payer must be adopted.'" We have scanned through the clarification issued by the Commissioner of Commercial Taxes, Thiruvananthapuram, annexure A III. It is clearly stated in the said clarification that the intention of the notification is very clear that the retrospective operation given to the reduction of the rate of tax shall not result in any outflow of money from the Government exchequer. It is clearly stated in the said clarification that the intention of the notification is very clear that the retrospective operation given to the reduction of the rate of tax shall not result in any outflow of money from the Government exchequer. He had also stated that if the argument of counsel for the appellants that the last paragraph of the notification is applicable only in the case of dealers, who have collected tax and paid to the Government, is accepted, it will lead to discriminating dealers paying tax at the point of sales against dealers who are paying tax at the point of purchase, attracting article 14 of the Constitution of India. We have also perused the judgment of the learned single judge, which is impugned in the writ appeals. The learned single judge had observed that the appellants did not question the validity of the notification. Thereafter the learned single judge considered the question regarding the scope of the clause extracted by us earlier in this judgment in the following manner : "The Government Pleader appearing for respondents contended that the notification does not provide for refund of tax, if already paid to the Government. Since the petitioners do not question the validity of the notification, there is no need to go into the validity of exhibit P1. The next question to be considered is as to what is the meaning to be assigned to the notification. The latter part of the notification has two aspects. First one is that tax collected at higher rate shall be paid over to the Government. This of course should be tax collected by the dealer from the buyers and retained by them without remittance to the Government. That such tax has to be paid to the Government is the scope of this part of the notification. The second part only says if the tax is already paid by the dealer at higher rate, the same shall not be refunded to them. The plain meaning of this part of the notification is that the petitioners who have remitted the tax at higher rate to the Government, are not entitled to refund. Their claim of refund is based on exhibit P1 by which reduction of tax is granted retrospectively. The plain meaning of this part of the notification is that the petitioners who have remitted the tax at higher rate to the Government, are not entitled to refund. Their claim of refund is based on exhibit P1 by which reduction of tax is granted retrospectively. The contention of the petitioners is that payment of tax referred to in the latter part of the notification also should be tax collected from the customers. In other words, prohibition against refund is only in respect of tax collected from customers and remitted to the Government. The contention of the petitioners is that there is no occasion to collect tax in respect of arecanut because it is taxable at purchase point and the petitioners being the last purchasers are paying tax without any collection of the same. Therefore, according to them, the bar contained in the notification does not apply to them at all. I do not think this proposition can be accepted because the four items covered by the notification are taxable at different points under the Schedule to the Act. While 'newsprint' and 'cardamon' are taxable at sale point, 'arecanut' and 'pepper' are taxable at last purchase point. Therefore, it is not as if the Government was not aware of the fact that there is no collection of tax in respect of items taxable at purchase point. When the Government puts a prohibition against refund of tax already paid, it cannot be assumed unless it is specifically stated in the notification that such tax is the tax collected from the buyers and remitted by the petitioners. Therefore, the latter part of the notification only prohibits refund of tax, if already paid by the petitioners. There is no further condition that the prohibition is only if the tax remitted is collected by the petitioners from the buyers. Therefore, I feel the notification covers two situations namely, .... (a) Tax collected at higher rate by the dealers from buyers should be recovered, if not paid to Department. (b) Tax paid to Government whether after collection or not should not be refunded. Therefore, I feel the notification covers two situations namely, .... (a) Tax collected at higher rate by the dealers from buyers should be recovered, if not paid to Department. (b) Tax paid to Government whether after collection or not should not be refunded. In view of this meaning assigned to the notification, I feel the petitioners are not entitled to refund of tax already paid, and if wrongly refunded, the same can be recovered from the petitioners." We are in full agreement with the conclusion reached by the learned single judge, for according to us, there is no justification for reading the two clauses of the last paragraph of the notification in conjunction. A reading of those clauses itself will show that it contemplates two different situations. One regarding the tax collected, and the other regarding the tax paid. The appellant's case falls squarely under the latter limb. Unless we read into the latter clause the word "collected" occurring in the first clause, the appellants cannot succeed in their case. According to us, we will not be justified in reading into the latter clause the word "collected", when the clause does not warrant such an interpretation. For all these reasons, we do not find any ground to interfere with the clarification issued by the Commissioner of Commercial Taxes in annexure A III order in M.F.A. No. 142 of 2002. This disposes of M.F.A. No. 142 of 2002 and the main contention in the writ appeals also. However, as already noted, there is one more contention in the writ appeals with regard to the notices issued under section 43 of the Act. We have declared the scope of the clause regarding retrospective application of the notification occurring in the last paragraph of the notification. We do not propose to deal with the notices issued under section 43 of the Act or regarding the assessment, which is the subject-matter of W.A. No. 118 of 2003. All these questions are relegated to the statutory authorities for disposal in the light of the decision taken on the scope and content of the clarification issued by the Commissioner of Commercial Taxes in annexure A III order. All these appeals are disposed of as above. Order on C.M.P. No. 725 of 2002 in M.F.A. No. 142 of 2002 dismissed.