JUDGMENT Bhaskar Bhattacharya, J.: This mandamus-appeal is at the instance of an unsuccessful writ petitioner and is directed against order dated September 17, 2003 passed by a learned Single Judge by which His Lordship dismissed the writ application filed by the appellant in which it challenged an order dated September 16, 2002, passed by the Special Secretary, Finance (Taxation) Department, Government of West Bengal thereby rejecting the application filed by the appellant claiming benefit under the West Bengal Industrial Promotion (Assistance to Industrial Units) Scheme. (Hereinafter referred to as the Scheme). 2. The case made out by the appellant in its writ application, which is the third one at the instance of the appellant, out of which the present mandamus-appeal arises, may be summed up thus: a) The appellant No. 1 carried on business of manufacturing Rice Bran Oil Grade-1 by solvent extraction process. Such oil manufactured by the appellant No.1 can only be used for human-consumption after further processing. The Rice Bran Oil Grade-1 is known, considered and accepted as Edible Rice Bran Oil. b) There are three types of Rice Bran Oil, namely, Refined Grade, Raw Grade-1, and Raw Grade-2. Refined Grade of Rice Bran Oil is used for direct human-consumption. The Rice Bran Oil Grade-1 which is manufactured by the appellant is of edible variety and is rendered fit for consumption only after processing whereas the Rice Bran Oil Grade-2 is not edible and can be used only for industrial purposes. c) The Government of West Bengal, Finance Department, formulated a Scheme known as West Bengal Industrial Promotion (Assistance to Industrial Units) Scheme in the year 1994 and the object of the said Scheme is to give financial assistance to the scheduled manufacturing units in the State of West Bengal. Under schedule "A", units engaged in the manufacture of "Edible Rice Bran Oil" are entitled to incentives as per item No.4. d) The appellant No. 1 made an application in order to get incentives under the said Scheme, but such application not having been processed, the appellant, in the past, filed a writ application being W.P. No. 1734 of 1998. The said writ application was disposed of by directing the concerned authority to give an opportunity of hearing to the appellant and to dispose of the same within a specified period by a reasoned order. The said writ application was disposed of by directing the concerned authority to give an opportunity of hearing to the appellant and to dispose of the same within a specified period by a reasoned order. e) On January 25, 1999, the Special Secretary, Finance Department, Government of West Bengal, disposed of the application by holding that the Rice Bran Oil Grade-1 manufactured by the appellant was not "Edible Rice Bran Oil" and therefore, the appellant was not entitled to get the incentives under the Scheme. f) Being dissatisfied, the appellant filed its second writ application before this Court being W.P. No. 1568 of 1999 challenging the said order dated January 25, 1999 passed by the Special Secretary, Finance. A learned Single Judge of this Court by order dated April 19, 2002 set aside the order passed by the Special Secretary, Finance, and directed him to give a fresh hearing in the matter in the light of the observations made in the order. g) By order dated September 16, 2002, the Special Secretary, Finance, again rejected the prayer of the appellant holding that the appellant was not entitled to get the benefit under the Scheme, as it does not manufacture "Edible Rice Bran Oil". Being dissatisfied, the appellant preferred its third writ application being W.P. No. 2170 of 2002. 3. The said writ application was contested by the State-respondent by filing affidavits-in-opposition and the sum and substance of the defence was that Edible Oil means that category of Oil, which is fit for direct human-consumption. According to the State-respondent, the Oil, which is made fit for human-consumption by further processing, cannot be said to be "Edible" in order to get the benefit of the Scheme. 4. A learned Single Judge of this Court by the order impugned herein has dismissed the said writ application thereby upholding the order dated September 16, 2002 passed by the Special Secretary, Finance (Taxation) Department, Government of West Bengal. 5. Being dissatisfied, the writ petitioners have come up with the present mandamus-appeal. 6. Mr. Mukherjee, the learned Senior Counsel appearing on behalf the appellants has vehemently contended before us that the learned Single Judge erred in law in approving the order passed by the Special Secretary, Finance by not at all dealing with the various contentions advanced by the appellants before His Lordship. The contentions put forward by Mr. 6. Mr. Mukherjee, the learned Senior Counsel appearing on behalf the appellants has vehemently contended before us that the learned Single Judge erred in law in approving the order passed by the Special Secretary, Finance by not at all dealing with the various contentions advanced by the appellants before His Lordship. The contentions put forward by Mr. Mukherjee before us may be epitomized thus: 1) The phrase "Edible Rice Bran Oil" not having been defined in the Scheme, the meaning given to it in the ordinarily trade circle to be accepted. That the Rice Bran Oil Grade-1 manufactured by the appellants is fit for human-consumption only after further processing and nevertheless, is considered as Edible Oil, both ordinarily and in the trade circle, will appear from the following documents annexed to the original writ application: a) Letter dated March 22, 1996 issued by the Ministry of Civil Supplies, Government of India annexed at page 67 of the writ application. b) Notification dated July 31, 1997 issued by the Ministry of Finance, Department of Revenue, which admits the fact that vegetable Oil of edible Grade will cover vegetable Oil, which is fit for human-consumption at the time of import as also the vegetable Oil, which can be fit for human-consumption after further processing. (Page 69 of the writ application). c) Notification dated April 19, 1987 issued by the Ministry of Finance, Government of India, saying that the edible Oil has to be understood as the Oil, which can be processed for edible purposes as distinct from that which is permitted for use of industrial purpose only. (Page 73 of the writ application). d) According to Edible Oil Seeds and Edible Oils (Storage Control). Fourth Amendment Order, 1990, Edible Oil means any Oil used directly or after processing for human-consumption and includes hydrogenated vegetable Oil. (Page 77 of the writ application). e) The Director, Oil Technological Research Institute, Jawaharlal Nehru Technological University, Ananthpur, by a letter dated June 29, 1997 made it clear that although Rice Bran Oil, Grade-1 is an edible Grade Oil, yet it is not meant for direct human-consumption. (Page 84 of the writ application). f) Dr. Manindra Mohan Chakraborty, former Professor of Applied Chemistry, Calcutta University and Vice-Chancellor, Jadavpur University is of the opinion that though Rice Bran Oil Grade-1 is not meant for direct human-consumption, it is considered as edible. (Page 87 of the writ application). (Page 84 of the writ application). f) Dr. Manindra Mohan Chakraborty, former Professor of Applied Chemistry, Calcutta University and Vice-Chancellor, Jadavpur University is of the opinion that though Rice Bran Oil Grade-1 is not meant for direct human-consumption, it is considered as edible. (Page 87 of the writ application). g) According to the Department of Grain Science and Technology, Ministry of Food Processing Industries, Government of India, Rice Bran Oil with less than 8 to 10 per cent FFA is considered acceptable and the said Oil is called Edible Rice Bran Oil in the trade. (Page 89 of the writ application). 2) The word "edible" cannot be equated with only something, which is fit for direct human-consumption. An item, which after further processing becomes fit for human-consumption, is also edible. The same will be clear from Rule 49 (13) of Prevention of Food Adulteration Rules, 1955, which says that all edible Oils, except Coconut Oil imported in crude, raw or unrefined form shall be subjected to the process of refining before sale for human-consumption. Therefore, Rice Bran Oil Grade-1 in its crude form before processing to make it fit for human-consumption is also edible. 3) The object of Scheme of 1994 is to give financial assistance to manufacturing units in the State of West Bengal engaged in the manufacture of Edible Rice Bran Oil. The appellant has its unit in West Bengal and therefore, in view of the object of the Scheme of 1994, the word "edible" should be liberally construed to achieve the object of the Scheme. 4) The trade meaning given to the term "Edible Oil" should be given preference and while interpreting a taxing statute, the provision for promoting economic growth and development should be liberally construed. When two views are possible, the one, which furthers the legislative intent, should be accepted. 5) The order passed by the Special Secretary, Finance, dated September 16, 2002 was on the face of it is bad in law inasmuch as the Special Secretary relied upon two decisions in arriving at the conclusion that the Rice Bran Oil Grade-1 is not edible when this Court in the earlier round of litigation clearly held that those two decisions are not at all relevant for deciding the controversy in the case. In support of the aforesaid contentions, Mr. In support of the aforesaid contentions, Mr. Mukherjee relied upon the following decisions: (i) Commissioner of Central Excise, Allahabad vs. Ginni Filaments Ltd., 2005(3) SCC 378 ; (ii) Transport Corporation of India vs. Employees' State Insurance Corpn. & Anr., reported in 2000(1) SCC 332 ; (iii) Collector of Central Excise vs. Alco Industries, reported in 1991(55) ELT 184 (Mad); (iv) Aditya Mills Ltd. vs. Union of India, reported in 1988 (37) ELT 471 (SC); (v) Collector of Customs, Bombay vs. Swastic Woollen (P) Ltd. & Ors., reported in 1988(37) ELT 474 (SC); (vi) Bajaj Tempo Ltd., Bombay vs. Commissioner of Income Tax, Bombay City-III, Bombay, reported in 1992(3) SCC 78 ; (vii) Commissioner of Income-Tax, Amritsar vs. Strawboard Manufacturing Co. Ltd., reported in 1989(177) ITR 431. 7. Mr. Gupta, the learned Senior Advocate appearing on behalf of the respondents has opposed the aforesaid contentions advanced by Mr. Mukerjee and has contended that the Special Secretary and the learned Single Judge of this Court on consideration of the materials on record have rightly decided that the Oil manufactured by the appellant being not fit for direct human-consumption, cannot be termed as "edible" so as to get the benefit of the Scheme. Mr. Gupta contends that the learned Single Judge correctly held that the Special Secretary gave fullest opportunity to the appellant as per earlier direction passed by this Court and after considering the materials placed by the appellant rightly turned down the benefit claimed by the appellants. According to Mr. Gupta, "Edible Oil" means something which is fit for direct human-consumption but something which becomes "edible" after further processing cannot be said to be "Edible Oil". Mr. Gupta points out that under the West Bengal Pulses Dealers Licensing Order, Rice Bran Oil, Grade-1 is not edible oil. Mr. Gupta in this connection relies upon the following decisions for the purpose of repelling the contentions of Mr. Mukherjee: (i) Markandey Singh, IPS. & Ors. Vs. M.L. Bhanot, IPS & Ors., reported in 1988(3) SCC 539 ; (ii) Union of India vs. Sankalchan Himatlal Sheth & Anr., reported in AIR 1977 SC 2328 ; (iii) State of Kerala vs. Mathai Verghese & Ors., reported in 1986(4) SCC 746 ; (iv) State Level Committee & Anr. Mukherjee: (i) Markandey Singh, IPS. & Ors. Vs. M.L. Bhanot, IPS & Ors., reported in 1988(3) SCC 539 ; (ii) Union of India vs. Sankalchan Himatlal Sheth & Anr., reported in AIR 1977 SC 2328 ; (iii) State of Kerala vs. Mathai Verghese & Ors., reported in 1986(4) SCC 746 ; (iv) State Level Committee & Anr. vs. Morgardshammar India Ltd., reported in AIR 1996 SC 524 ; (v) Munishwar Dutt Pandey vs. Ramjeet Tiwari & Ors., reported in AIR 1997 SC 1571 ; (vi) Bharat General and Textile Industries Ltd. & Ors. vs. State of Maharashtra & Ors., reported in 1989(72) Sales Tax Cases 354; (vii) State of Goa & Ors. vs. Leukoplast (India) Ltd., reported in 1997(4) SCC 82 ; (viii) Chhatar Extractions Put. Ltd. vs. Excise and Taxation Commissioner, Punjab, Chandigarh & Anr., reported in 1986(61) Sales Tax Cases 374. 8. After going through the materials on record, we find that the Special Secretary, Finance, by the order dated September 16, 2002, first relied upon two decisions, one in the case of Chandausi Oil Mills, Chandausi, Moradabad vs. Sales Tax Commissioner, U.P., reported in 1961(12) Sales Tax Cases 310 and the other, in the case of Chattar Extraction Private Ltd. vs. The Excise and Taxation Commissioner, reported in 61 STC 374 in arriving at the conclusion that the Rice Bran Oil manufactured by the appellant is not "edible" so as to get the benefit of the notification. At this stage, it may not be out of place to mention here that in the second round of litigation before this Court, the learned Single Judge dealing with the writ application while setting aside the order of the Special Secretary, Finance, explicitly held that those two decisions were not applicable in deciding the dispute involved in the present case. The State-respondent did not prefer any appeal against the order of the learned Single Judge and had accepted the said decision and consequently, decided the matter afresh. While deciding the said matter pursuant to the order of the learned Single Judge, it was improper on the part of the Special Secretary to rely upon those very two decisions. We, therefore, find substance in the contention of Mr. Mukherjee, the learned Senior Advocate appearing on behalf of the appellants that the State respondent could not rely upon those two decisions over again for the purpose of deciding the dispute. 9. We, therefore, find substance in the contention of Mr. Mukherjee, the learned Senior Advocate appearing on behalf of the appellants that the State respondent could not rely upon those two decisions over again for the purpose of deciding the dispute. 9. It further appears from the order passed by the Special Secretary that he also placed reliance upon the letter of Jawaharlal Nehru Technological University referred to by the appellants ill holding that although Rice Bran Grade-1 Oil is recognised as edible Oil, the same is not fit for direct human-consumption. The concerned officer thought it fit to refer to the letter written by Professor M. M. Mukherjee in holding that the Rice Bran Oil Grade-1 is defined as edible Rice Bran Oil because it is used for edible purposes while the Rice Bran Grade-2 is used for industrial need. The said officer further took support from the booklet published by the Department of Grain Science and Technology, Central Food Technological Research Institute wherein it has been mentioned that Rice Bran Grade-1 Oil is used for manufacturing Vanaspati and accordingly, the same cannot be said to be edible. The said officer further found substance in the observation at page 50 indicating that there is a lot of difference in characteristics of Refined Grade from Refined Grade-1. After considering those materials, the Special Secretary dealt with the well-settled principles of interpretation of statute that in order to get exemption in a fiscal statute, the same should be strictly construed, otherwise, there will be loss from the public exchequer. Ultimately, the Special Secretary rejected the representation of the appellant. The Special Secretary, however, did not even refer to other authorities relied upon by the appellant. 10. The learned Single Judge, as it appears from the order impugned herein, has virtually repeated the observations of the Special Secretary and relied upon the two decisions referred to above. In addition to those decisions, the learned Single Judge relied upon the decision of the Supreme Court in the case of Giridharilal Mal Kapur Chand vs. Debraj Madan Gopal, reported in AIR 1963 SC 1587 wherein the Supreme Court held that the Cotton seed' is an Oilseed but the same is not fit for human-consumption and therefore, its Oil is also not edible. His Lordship further took note of the definition of edible Oil appearing in section 3 of the Essential Commodities Act, which says that Edible Oil means any Oil used directly, or after processing for human-consumption and includes Hydrogenated Vegetable Oil. Ultimately, His Lordship, however, found no reason to interfere with the order passed by the Special Secretary and therefore, dismissed the writ application. 11. After hearing the learned Counsel for the parties and after going through the materials on record, we find that in the Scheme there is no definition of "Edible Rice Bran Oil". However, from the materials on record, we find that there are three grades of Rice Bran Oil, namely, Refined Grade, Raw Grade-1 and Raw Grade-2. The Refined Grade of Rice Bran Oil is fit for direct human-consumption whereas Raw Grade-1 is of edible variety and is rendered fit for human-consumption after further processing. On the other hand, the Rice Bran Oil of Raw Grade-2 category is not edible at all and is used only for industrial purpose. 12. The Rice Bran Oil Raw Grade-1 is used by the Vanaspati industry. The various Vanaspati manufacturers refer to the said Rice Bran Oil of Raw Grade-1 is Edible Rice Bran Oil. The Directorate of Vanaspati, Vegetable Oils and Fats of the Government of India considers Rice Bran Oil Raw Gradel obtained by the method of solvent extraction as Edible Oil permitted to be used in the manufacture of Vanaspati as would appear from the letter dated March 22, 1995 issued by the said Directorate. By a notification dated March 1, 1997, the Government of India granted Custom Duty exemption in respect of imported Vegetable Oil of Edible Grade. In this context, a question arose as to whether the same covered only those Vegetable Oils, which were fit for human-consumption as imported or also included the Vegetable Oil, which is rendered fit for human-consumption after further processing. It further appears that the Government of India by a notification dated July 31, 1997 made it clear that the term "Vegetable Oils of Edible Grade" would cover Vegetable Oils, which was fit for human-consumption at the time of import as also the Vegetable Oils, which were rendered fit for consumption after processing. It was further clarified that the benefit of Duty Exemption would be admissible so long as the imported oil was used for Edible purposes even after refining. 13. It was further clarified that the benefit of Duty Exemption would be admissible so long as the imported oil was used for Edible purposes even after refining. 13. Previously, the Central Government by notification dated March 1, 1986 granted Excise Duty exemption in respect of Vegetable products made, inter alia, from Rice Bran Oil of Edible Grade which was defined in the explanation contained in the said notification as meaning Rice Bran Oil which conformed to the standard of quality of Edible Oil specified for Rice Bran Oil in the Prevention of Food Adulteration Rules of 1956 under the Prevention of Food Adulteration Act, 1954. In the context of the said notification, the Government of India by a circular dated April 9, 1987 after considering the provisions of the Prevention of Food Adulteration Rules of 1956 and the Solvent Extracted Oil, De-Oiled Meal and Edible Flour (Control) Order, 1967 clarified that the term Edible Oil used in the explanation had to be understood as the Oil which would he processed for edible purposes as distinct from that which was permitted for use in industrial processes only. It was, thus, clear that the Government of India all anong considered Rice Bran Raw Grade-1 as an Edible Grade product. 14. It will not be out of place to mention here that the Central Government in the exercise of its power under section 3 of the Essential Commodities Act, 1955 made the Pulses, Edible Oil Seeds and Edible Oil (Storage Control) Order, 1977. 2(g) of the said Order as amended by the notification dated September 30, 1990 defined Edible Oil to mean any Oil used directly or after processing for human-consumption and included Hydrogenated Vegetable Oil. Therefore, Rice Bran Oil Raw Grade-1 is Edible Oil according to the said order. 15. What is a more striking is that by a Notification dated March 29, 1994 issued by the Government of West Bengal in exercise of the power conferred by section 25 of the West Bengal Sales Tax Act, 1954, several commodities were transferred from the purview of the Bengal Finance (Sales Tax) Act, 1941 to that of the West Bengal Sale Tax Act of 1954. By the said Notification, the Edible Oil was also transferred. The term "Edible Oil" was started in the said notification to mean, inter alia, Rice Bran Oil. By the said Notification, the Edible Oil was also transferred. The term "Edible Oil" was started in the said notification to mean, inter alia, Rice Bran Oil. It further appears that the Commercial Tax Authorities had levied Sales Tax in respect of the appellant's products, namely, Rice Bran Oil Raw Grade-1 on the basis of the said Notification and accordingly, the same was construed to be Edible Oil for the purpose of imposition of Sales Tax. 16. It is, therefore apparent that in the ordinarily and trade parlance, edible oil does not necessarily mean only those types of oils which are fit for direct human-consumption. It further appears from the various Government Notifications mentioned above that the term "edible oil" means not only that kind of the oils which is fit for direct human-consumption but also those categories of oil which would become fit for direct human-consumption after further processing as distinguished from those classes of oil which are used for industrial purposes only and consequently, the Rice Bran Oil Grade-1 which after processing becomes fit for human-consumption are regarded as edible oil in trade parlance. We have already indicated that the State Government has even realised Sales Tax from the appellant for the selfsame Rice Bran Grade-1 Oil by treating the same as edible oil. Therefore, it will be inappropriate to accept the submission of the State Government that the oil, which is only fit for direct human-consumption is "edible oil" by solely relying upon the definition given in the West Bengal Pulses Dealers Licensing Order particularly when the same State Government realises Sales Tax from the appellant for the identical products by treating the same as edible oil. 17. We have already pointed out that the Special Secretary as well as the learned Single Judge ought not to have relied upon the decisions, which were found to be not reliable in the facts of the present case by this Court in the second round of litigation as the said order is binding upon the parties and has attained finality. 18. The observation of the Special Secretary that the letters written by the Jawaharlal Nehru Technological University and Professor M. M. Chakraborty do not support the contention of the appellant is equally devoid of any substance. 19. 18. The observation of the Special Secretary that the letters written by the Jawaharlal Nehru Technological University and Professor M. M. Chakraborty do not support the contention of the appellant is equally devoid of any substance. 19. It appears from the order passed by the Special Secretary that he quoted a portion of the letter written by the Jawaharal Nehru Technological University wherein it was mentioned that as per gradation, the material of Raw Grade-1 is used for making 'Vanaspati' and 'Refined Oil' and not for direct human-consumption. The said Special Secretary further quoted the observation that Rice Bran Oil Grade-1 is edible grade oil but it is not meant for direct human-consumption as it is a solvent extracted oil. It proceeded further that any solvent extracted oil is not meant for direct human-consumption even though it is of edible grade unless and until the oil is refined, bleached and deodorised. The report further disclosed that oils like Soybean, Groundnut, Sunflower and Mustard, though all of them are of edible grade, are to be refined to make the oils fit for human-consumption because those are produced by solvent extraction method. 20. In our view, there being no definition of edible oil within the four corners of the Scheme, the fact that a particular type of oil cannot be used for immediate direct human-consumption is immaterial for the purpose of interpreting the Scheme. Even the report of the Jawaharlal Nehru Technological University itself shows that Rice Bran Oil Grade-1 is edible oil. Therefore, the Special Secretary totally misread those observations made in the letter written by the Jawaharlal Nehru Technological University where Rice Bran Grade-l Oil has been described as edible oil notwithstanding the fact that it is not fit for direct human-consumption. 21. Similarly, the letter of Professor M. M. Chakraborty has also been misconstrued. Professor Chakrubarty has also specifically opined that in fact, the Rice Bran Oil Grade-1 is considered edible though not meant for direct human-consumption. Similarly, the booklet published by the Department of Grain Science and Technology, Central Food Technological Research Institute, Mysore and the comparative table of Indian Standard Specification for Rice Bran Oil has been misinterpreted by not considering the other part of those reports. Similarly, the booklet published by the Department of Grain Science and Technology, Central Food Technological Research Institute, Mysore and the comparative table of Indian Standard Specification for Rice Bran Oil has been misinterpreted by not considering the other part of those reports. All those reports at least unmistakably points out the trade meaning of the words "Edible Oil" to denote the oil which is not only suitable for direct human-consumption but also the one which can be made fit after further processing. 22. We have already indicated that whether the Rice Bran Grade-1 Oil would be entitled the benefit of the Scheme is the question before us and for the above purpose whether such oil is fit for direct human-consumption or not is not at all material. We have already mentioned that the same Grade of Oil is charged for Sales Tax as "edible oil" by the Government of West Bengal and in the absence of any definition of edible oil in the Scheme itself, in our opinion, the trade meaning should be given effect to. 23. We, therefore, find that the approach of the Special Secretary, Finance, is totally erroneous, particularly, in view of the earlier direction given to him by this Court in the second round of litigation. 24. We have already pointed out that the learned Single Judge has virtually reiterated the reasons assigned by the Special Secretary, Finance and in addition to that has relied upon the decision of the Supreme Court in the case of Girdharlal Mal Kapur Chand vs. Debraj Madan Gopal (supra) where the Supreme Court held that the cotton seed is not edible and, therefore, the oil extracted from such seed was not edible oil. Before relying upon any observation recorded in a decision of the Supreme Court, it is the duty of a Court to bear in mind the context in which the Supreme Court made such observation. In the case of Girdharlal Mal Kapur Chand (supra), the Supreme Court made the aforesaid observation while construing the provisions contained in Essential Supplies (Temporary Power) Act, 1946. The term "essential commodity" was defined in section 2 of the said Act to mean any of the following classes of commodities: (1) Foodstuffs, (2) Cotton and Woollen textiles, (3) Paper, (4) Petroleum and petroleum products, (5) Spare patrtis of mechanically propelled vehicles, (6) Coal, (7) Mica. The term "essential commodity" was defined in section 2 of the said Act to mean any of the following classes of commodities: (1) Foodstuffs, (2) Cotton and Woollen textiles, (3) Paper, (4) Petroleum and petroleum products, (5) Spare patrtis of mechanically propelled vehicles, (6) Coal, (7) Mica. The word "Foodstuffs" was defined thus: "Foodstuffs shall include Edible oil seeds and oils." The question before the Supreme Court was whether cotton seed was foodstuff within the meaning of the Act. In that contest, the Supreme Court observed that the cotton seed is an oilseed but it cannot be for a moment be suggested that it is fit for human-consumption. Therefore, according to the Supreme Court it is not an oilseed, which is edible. The Supreme Court in that context had rejected the contention of the learned Advocate for the appellant that "edible oil seed" means edible seed from which edible oil can be prepared by making the following observations: "Such an argument has only to be mentioned to deserve rejection. The phrase "edible oil-seed" can never mean what the learned Counsel suggests and can and does mean only an oil seed which is edible as an oil-seed. Cotton-seed, not being edible, falls outside the class of "edible oil-seed" and so is not foodstuff within the meaning of section 2 of the Ordinance or the Act of 1946." 25. In the case before us, the question is whether the appellant is dealing with Edible Rice Bran Oil so as to get the benefit of the Scheme. As mentioned earlier, the Rice Bran Oil available in the market is principally of three different varieties. The first one is called Refined Grade, which can be used for human-consumption without any further processing. The second category is called Rice Bran Grade-1 dealt with by the appellant, which can be made fit for human-consumption only after further processing and the third one, which is called Rice Bran Grade-2, is used only for industrial purpose. In the fact of the present case, in our opinion, the first two categories should be called edible oil and not the third one, which is used only for industrial purpose when so many Government notifications have recognised those two grades as "edible" and the State of West Bengal itself has realised Sales tax from the appellant for the selfsame item. Moreover, as pointed out by the Apex Court in the case of Aditya Mills Ltd. vs. Union of India, reported in 1988(37) ELT 431, for ascertaining a correct meaning of a fiscal entry even in a taxing statute, reference to a dictionary is apt to be a somewhat delusive guide as it gives all the different shades of meaning and in such a situation, the trade meaning should be given preference. Therefore, the decision of the Supreme Court in the case of Girdharlal Mal Kapur Chand (supra), cannot have any application to the fact of the present case. 26. We now propose to deal with the decisions cited by Mr. Gupta. 27. In the case of Bharat General and Textile Industries Ltd. & Ors. vs. State of Maharashtra & Ors. (supra), the Supreme Court held that it was open to the State Government under section 41 of the Bombay Sales Tax Act, 1959 to give the benefit of tax exemption either in full or to a partial extent and the section itself stated that the power of exemption was being conferred on the Government in order to enable it to act in public interest. According to the Supreme Court, it was not correct to say that the power had been given to the Government to act in an arbitrary manner or for conferring larges on any section of manufacturers or traders. In the said case, under the provision of the statute, the sales tax exemption facility originally granted under the Package Scheme of Incentives, 1979 to all small scale units newly started stood withdrawn and was limited to only in so far as edible oil units were concerned and not to small-scale units engaged in producing non-edible oils. By a trade circular dated October 15, 1986 it was clarified that the edible oil unit under the said Act would mean a unit engaged in 1) delinting, decorticating, or processing of ground nuts or other oil-seeds; 2) erushing of ground nuts or other oilseeds; 3) refining of edible oil; 4) hydrogenation of edible oil. By a trade circular dated October 15, 1986 it was clarified that the edible oil unit under the said Act would mean a unit engaged in 1) delinting, decorticating, or processing of ground nuts or other oil-seeds; 2) erushing of ground nuts or other oilseeds; 3) refining of edible oil; 4) hydrogenation of edible oil. It was also clarified that the Act would not be applicable to the units producing and selling non-edible oil and that the units manufacturing and selling washed cottonseed oil, Soybean raw oil (grade-1) and unrefined sunflower cake oil would not full under the category of the units manufacturing edible oil and those units would not get the benefit of tax exemption. It was contended before the Supreme Court that washed cotton seed oil would also fall in the category of edible oil. The Supreme Court negatived the said contention. In our view, the aforesaid decision cannot be relied upon for the purpose of showing that refined Rice Bran Oil Grade-1 is not an edible oil as in the Scheme before us there is no definition of any edible oil whereas in the case before the Supreme Court "washed cotton seed oil" was specifically excluded from the meaning of edible oil. Therefore, the said decision cannot help the respondent in any way. 28. In the case of Munishwar Dutt Pandey vs. Ramjeet Tiwari & Ors., (supra), the Supreme Court reiterated the well-settled proposition of law that the Preamble of a statutory instrument cannot control the express clear language and the sweep of the operating provisions of an instrument nor can the express language of a statutory provision be curtailed or read down in the light of the Preamble in the absence of any ambiguity in the enacted provision. In the case before us there being no definition of edible oil in the Scheme, we fail to appreciate how the said decision can, in any way, help Mr. Gupta's client. 29. In the cast of State Level Committee & Anr. vs. M/s. Morgardshammar India Ltd. (supra), the well-settled proposition of law that the provision providing for exemption in a taxing statute has to be strictly construed has been reiterated. The Supreme Court in the said case held that when two views of exemption notification are possible, it should be construed in favour of the State. By relying upon the said decision, Mr. The Supreme Court in the said case held that when two views of exemption notification are possible, it should be construed in favour of the State. By relying upon the said decision, Mr. Gupta tried to contend that we should take a strict approach and for the purpose of giving effect to the intention of the Government, the oil, which is ready for direct human-consumption, should be chosen. We are however unable to accept the contention for two reasons. First, the Scheme, which we are dealing with, is not a Taxing Statute nor are we concerned with an exemption clause in such a Statute. Rere is a beneficial scheme the object of which is to give benefit to the investors in the State in certain fields of business and in construing the Scheme, we should bear in mind the intention of the Government to attract investors and when two views are possible, the one which furthers the intention behind it should be preferred to the one which would frustrate the same. (See Transport Corporation of India vs. Employees State Insurance Court, reported in 2000(1) SCC 332 ; Commissioner of Income Tax vs. Strawboard Manufacturing Co. Ltd., reported in 1989(177) ITR 431; Secondly, if there were any definition of edible oil in the Scheme itself indicating the intention to deprive the manufacture of the oil, which cannot be used for immediate human-consumption of the benefit, we would have readily accepted the contention of Mr. Gupta. In the absence of such definition, we are unable to approve the contention of Mr. Gupta that we should interpret the word "edible oil" in such a way that less number of applicants gets the benefit of the Scheme and for the above purpose we should add the phrase "fit for direct human consumption" in the Scheme which is totally impermissible. 30. In the case of State of Kerala vs. Mathai Verghese & Ors., (supra), the Supreme Court reiterated the well-settled proposition of law that the Court can merely interpret a provision so as to make explicit the intention of the legislature. According to the Supreme Court, it cannot rewrite, recast or redesign the provision since the power to legislate has not been conferred on the Court. According to the Supreme Court, it cannot rewrite, recast or redesign the provision since the power to legislate has not been conferred on the Court. It was further held that the Court should make a purposeful interpretation so as to effectuate the intention of the legislature and not a purposeless one in order to defeat the intention of the legislators wholly or in part. In the case before us, the intention of the Scheme was to give benefit to the units, which were manufacturing Edible Rice Bran Oil. From various documents produced before us and from the various statutory provisions as well as Government Notifications, we have gathered that edible oil has been given a wider meaning so as to distinguish the same from those oils which are used solely for industrial purpose and even if a particular oil is not ready for human-consumption but can be made so fit after further processing, such types of oil have been called edible. In the case before us, we have already pointed out that the State Government realised Sales Tax from the appellant for the self-same oil as if the same is edible oil; in such circumstances, it will be improper not to give them the benefit of edible oil while construing the Scheme in question. 31. In the case of Union of India vs. Sankalchand Himatlal Sheth & Anr. (supra), it was held that where the statutory meaning is clear and explicit, words cannot be interpolated. According to the Supreme Court, what is true of the interpretation of an ordinary statute is not any the less true in the case of a Constitutional provision and the same rule applies equality to both. But if the words of an instrument are ambiguous in the sense that they can reasonably bear more than one meaning, that is to say, if the words are semantically ambiguous or if a provision, if read literally, is patently incompatible with the other provisions of that instrument, the Court would be justified in construing the words in a manner which will make the particular provision purposeful. In the case before us, in the absence of any definition of edible oil in the Scheme, there is no scope of construing the said term in comparison to the words used in other part of the Scheme and, therefore, the meaning that will be appearing in the trade parlance should be given effect to. 32. In the case of Mankandey Singh & Ors. vs. M. L. Bhanot & Ors., (supra), it was held that if the words of a statute are in themselves precise and unambiguous, nothing more is necessary than to expound these words in their natural and ordinary meaning, since, the words themselves, in such a case, is best guiding factor declaring the intention of the legislature. If we apply the said principle to the fact of the present case, there is no scope of construing the same as meaning "ready for direct human-consumption" and if we want to construe the word in that fashion, we will be adding words to the Statute, which is impermissible for a Court of law whose duty is not to legislate. 33. In the case of State of Goa vs. Leucoplast (India) (supra), the question was whether the products manufactured by the assessee could be treated as "drugs or medicines". The Supreme Court held that such question could not be answered straightway. According to the Supreme Court, the medicinal content of the product, if any, had to be ascertained and its curative function had to be found out. Those were, the Supreme Court proceeded, questions of fact and could not be decided by reference to any .definition of the Drugs and Cosmetics Act or product control licence issued by the Drug Controller. There is also no definition given in the local Sales Tax Act or in the Central Sales Tax Act of these terms and such questions should be agitated before the statutory appellate authority. According to the Supreme Court, the assessee could not move the Writ Court without following the statutory remedy. In the case before us, the appellant had approached the special secretary, finance twice and as such, no question of bypassing any statutory remedy arises in the case before us. The said decision is therefore of no help to Mr. Gupta's client. 34. In the case of Chhattar Extraction Put. In the case before us, the appellant had approached the special secretary, finance twice and as such, no question of bypassing any statutory remedy arises in the case before us. The said decision is therefore of no help to Mr. Gupta's client. 34. In the case of Chhattar Extraction Put. Ltd vs. Excise and Taxation Commissioner (supra), the Punjab High Court was considering the question whether the notification issued by the State Government granting concessional rate of tax to the edible oil was available to the writ petitioner who was manufacturing Rice Bran Oil which was not refined enough to be fit for human-consumption. In the context, the High Court relied upon the provisions contained in the Prevention of Food Adulteration Rules, 1955 prescribing that the Rice Bran Oil should be sold for human-consumption only after refining. According to the High Court, the Rice Bran Oil, which is not refined, is not fit for human-consumption and therefore, cannot be said to be edible. By relying upon the said decision, Mr. Gupta tried to impress upon us that we should follow the aforesaid interpretation. We are afraid, with great respect to the learned Single Judge of the Punjab High Court, we are unable to accept such contention. It is a settle law that the definition given in one statute cannot be used for the purpose of construing the meaning of the same word figuring in a different statute if the objects of the two statutes as different. The object of the Food Adulteration Act and the Rules framed thereunder is to prevent the sale of unhealthy products for human-consumption whereas the object of the Scheme, we are concerned, is to give the incentive to the manufacturers of different items mentioned in the Scheme for encouraging them to invest money for the business in this State. Therefore, meaning given in the Prevention of Food Adulteration Act or the Rules framed thereunder cannot have any application for the purpose of giving meaning to a particular word in the Scheme before us. We are, therefore, unable to follow the said decision of the Punjab High Court as a precedent in the present case. 35. In the case Chandausi Oil Mills (supra), a. Division Bench of the Allahabnd High Court was considering the question whether linseed oil is edible oil within the meaning of Notification No. S.T. 117/S923/1948, dated 8th June, 1948. We are, therefore, unable to follow the said decision of the Punjab High Court as a precedent in the present case. 35. In the case Chandausi Oil Mills (supra), a. Division Bench of the Allahabnd High Court was considering the question whether linseed oil is edible oil within the meaning of Notification No. S.T. 117/S923/1948, dated 8th June, 1948. In answering the question, the Court relied upon the decision of a learned Single Judge of the said Court in the case of Kamla Kant Misra vs. State, reported in 1951 ALJ 348 where it was held that the word "edible" as used in section 2 of the U.P. Oil Seeds and Oil Seeds Product Control Order, 1945 should be interpreted to mean "fit to be eaten as food". The Control Order of 1945 was one of the Orders passed under the Essential Supplies (Temporary Powers) Ordinance, 1946, which was, repealed by section 17 of the Act XXIV of 1946. Clause (a) of section 2 provided that "essential commodity" meant any of the classes of commodities mentioned in that clause and those included "foodstuffs" and in clause (c) of the same section "Foodstuffs" had been defined as including "edible oil seeds and oils". In such circumstances, the Court proceeded to find the meaning of the word "edible" from various dictionaries and came to the conclusion that the same meant something "fit to be eaten as food". We have already pointed out that in the previous round of litigation, this Court while remanding the matter back to the Special Secretary, Finance specifically observed that this decision is not relevant for deciding the dispute involved herein, but in spite of such observation, the said officer relied upon the selfsame decision. We have also pointed out that in this type of a case, in the absence of any definition of "edible oil" appearing in the concerned Scheme, instead of following the dictionary meaning, the sense prevailing in the trade parlance should be the appropriate course to be followed as pointed out by the Supreme Court in the case of Aditya Ltd. (supra), and also in the case of Collector of Custom vs. Swastic Woolen (P) Ltd., reported in 1988(87) ELT 474. We, therefore, find that the said decision is of no avail to the State-respondent. 36. None of the decisions referred to by Mr. Gupta, therefore, helps his client in any way. 37. We, therefore, find that the said decision is of no avail to the State-respondent. 36. None of the decisions referred to by Mr. Gupta, therefore, helps his client in any way. 37. We, consequently, rind that, in the case before us, the Special Secretary, Finance, as well as the learned Single Judge misconstrued the word "edible oil" appearing in the Scheme in holding that the same should be interpreted to mean those qualities of oils which can be readily used for immediate human-consumption without further processing by overlooking the various materials produced by the appellant and the most significant point, overlooked by both the learned Single ,Judge and the Special Secretary, Finance, was that the State Government itself treated the same Rice Bran Oil Grade-1 as edible oil for the purpose of collecting the Sales Tax from the appellant whereas refused to grant benefit of the Scheme by treating the same as edible. 38. We, therefore, set aside the order passed by the Special Secretary and the learned Single Judge and hold that the manufacture of Rice Bran Oil Grade-1 which is used for human-consumption only after further processing as distinguished from the ones which are used for industrial purpose should get the benefit of the Scheme. 39. We, accordingly, allow the appeal and direct the State-respondent to give the benefit of the Scheme to the appellant No. 1 for the quarter ending June, 1994 and onwards which the appellant No. 1 is entitled. 40. In the facts and circumstances, there will be, however, no order as to costs. Kishore Kumar Prasad, J.: I agree. Appeal allowed.