Per Virender Singh, J.— 1. May be the instant case is initially styled as Reference under Section 35G of the Central Excise Act, 1944 (for short 'the Act'), learned counsel for both the sides conceded at the bar that it may be considered as an appeal assailing the impugned order No. A/56/07/C-II/EB dated 18.12.2006 passed by the Customs/Excise and Service Tax Appellate Tribunal (for short 'the Appellate Tribunal'). 2. At the very outset, it needs to be mentioned that the respondent-Unit had raised preliminary objection regarding the maintainability of the present appeal, inasmuch as exemption notification has direct proximity with the rate of duty, as such, under Section 35G of the Act no appeal would lie before the High Court but only before the Hon'ble Supreme Court under Section 35L of the Act. The said objection was dealt with in detail and held that the question involved in the case on hand is, whether the respondent-Unit has satisfied with the locational eligibility, which has no relation with the rate of duty or value of goods for the purposes of assessment and that being the factual and legal position, the appeal filed by the Union of India was held to be maintainable under Section 35G of the Act. It is thereafter the appeal on hand was admitted to hearing vide order dated 26.03.2008 formulating the following question of law:- "Whether, in the absence of any specific mention in Notification No. 79/2003-CE dated 22.12.2003, the Hon'ble Tribunal is correct in granting retrospective effect to the said Notification and remanding the case for grant of benefit based on such retrospective effect." 3. To appreciate the entire issue in its right perspective, brief facts of the case needs to be gone into. 4. The respondent-Unit claimed benefit from central excise duty, in terms of para (3) (a) of Notification No. 56/2002-CE dated 14.11.2002 (For short 'Notification No. 56'), whereby exemption from central excise duty to industrial units located in the State of Jammu and Kashmir in the areas specified in Annexure-II appended to the said notification has been granted. The respondent-unit is situated in 'SIDCO Industrial Complex, Bari Brahmana, Jammu', which, according to the appellant was not specified in Annexure-II of Notification No. 56 and the area specified was only 'EPIP, Kartholi, Bari Brahmana'. Accordingly, the respondent-unit was denied the benefit of notification No. 56. 5. The respondent-unit is situated in 'SIDCO Industrial Complex, Bari Brahmana, Jammu', which, according to the appellant was not specified in Annexure-II of Notification No. 56 and the area specified was only 'EPIP, Kartholi, Bari Brahmana'. Accordingly, the respondent-unit was denied the benefit of notification No. 56. 5. Subsequently, an amendment was issued vide notification No. 79/2003-CE dated 12.12.2003 (For short 'Notification No. 79), under which the entry 'EPIP Kartholi, Bari Brahmana' was substituted by the entry 'SIDCO Industrial Complex, Bari Brahmana, or EPIP Kartholi or village Kartholi or village Birpur'. The respondent-Unit claimed that this amendment in Notification No. 79 was clarificatory in nature covering the locational eligibility of the unit, as such, would have retrospective effect but the said plea was not accepted by Lower authority (Commissioner of Central Excise and Customs). Accordingly, the respondent-unit was denied the exemption vide order dated 25.04.2005 passed by the Commissioner of Central Excise and Customs. The operative part of the said order reads:- "(a) I upheld the show cause notice issued vide C. No. V(CE)Refd./ALU/71/03/4954 dated 25.03.2004 to Alu Bond Enterprises Phase-I, Lane no. 4, SIDCO Industrial Complex, Baribrahmana Jammu and reject the refund claims amounting to Rs. 24,83,890/-, Rs. 25,65,976/- and Rs. 18,53,327/- for the months of June, 2003, August 2003 and September 2003 respectively under Notification No. 56/2002-CE dated 14.11.2002. (a) I confirm the demand of Rs. 1,27,46,215/-against M/s Alu Bond Enterprises Phase-I, Lane No. 4, SIDCO Industrial Complex, Baribrahmna Jammu, under Section 11-A of the Central Excise Act, 1944. (b) I impose a penalty of Rs. 1,27,46,215/- upon the party under Rule 25 of Central Excise Rules, 2002 read with Section 11 AC of the Central Excise Act, 1944. (c) Interest as applicable rates should also be paid by the party under Rule-8 of Central Excise Rules, 2002." 6. Aggrieved of the aforesaid order dated 25.05.2005 passed by the Commissioner Central Excise and Customs, Jammu, the respondent-unit preferred an appeal before the Appellate Tribunal. The Appellate Tribunal vide order dated 18.12.2006 remanded the matter to the original adjudicating authority observing: - "We have considered the submissions. We find from Annexure-II annexed to notification 56/2002 that the area specified is EPIP, Kartholi, Baribrahmna alongwith their Khasra number which includes Khasra No. 394 also. The Appellate Tribunal vide order dated 18.12.2006 remanded the matter to the original adjudicating authority observing: - "We have considered the submissions. We find from Annexure-II annexed to notification 56/2002 that the area specified is EPIP, Kartholi, Baribrahmna alongwith their Khasra number which includes Khasra No. 394 also. It is the appellants' contention that Khasra No. 394 does not belong to EPIP, Kartholi but only to SIDCO Industrial Complex, Baribrahmna and therefore once the Khasra number was specified the benefit of the exemption should not have been denied taking into view the subsequent amendment which clarified the portion beyond doubt. We hold that once Khasra No. 394 has been mentioned in Annexure-II to the notification and the same comprises only of SIDCO Industrial Complex, Baribrahmna, then the benefit of notification should not have been denied. However, there is no evidence to establish that Khasra No. 394 had only SIDCO Industrial Complex on it and not the EPIP, Kartholi, Baribrahmna and therefore we remand the matter to the original adjudicating authority to verify if Khasra No. 394 comprise only of SIDCO Industrial Complex, Baribrahmna and not of EPIP, Kartholi and if the same is found to be correct he should extend the benefit of notification to the appellants." 7. Aggrieved of the order passed by the Appellate Tribunal, Commissioner of Central Excise and Customs, J&K, Jammu has preferred the instant appeal seeking quashment of the said order and restoration of the order passed by Commissioner of Central Excise and Customs, J&K, Jammu dated 25.04.2005. 8. Primarily in the flashback of these facts, the instant appeal stands admitted formulating the question of law as referred to hereinabove in para No. 2. 9. We have heard Mr. Magoo, learned counsel appearing for the appellant-Department and M/s Malik and.Kohli, learned counsel appearing for the respondent-Unit. 10. Mr. Magoo submits that the respondent-Unit was entitled to the exemption benefit under Notification No. 56 only from the date of amendment i. e., 22.12.2003 and not prior to that, as the unit was not falling in any specified area in Annexure-II appended to the said notification, therefore, not qualifying the locational eligibility. 10. Mr. Magoo submits that the respondent-Unit was entitled to the exemption benefit under Notification No. 56 only from the date of amendment i. e., 22.12.2003 and not prior to that, as the unit was not falling in any specified area in Annexure-II appended to the said notification, therefore, not qualifying the locational eligibility. This was the reason that the refund claimed by the respondent-Unit was rejected by Commissioner, Central Excise and Customs vide order dated 25.04.2005 but reversed by the Appellate Tribunal observing that once Khasra No. 394 has been mentioned in the notification and the same comprises only of SIDCO Industrial Complex, Bari Brahmana, the benefit of notification should not have been denied. 11. According to the learned counsel, it is only by Notification No. 79, whereby the amendment is made to the basic Notification No. 56, in Annexure-II under heading, 2-JAMMU PROVINCE', in sub heading 'I-DISTRICT JAMMU', under heading (C) 'Existing Location run by the Directorate of Industries and commerce', in the table, against serial No. 2, in column 'Name of the industrial area' for the entry 'EPIP Kartholi Bari Brahmana', the entry 'SIDCO Industrial Complex, Bari Brahmana or EPIP Katholi or village Kartholi or village Birpur', has been included, which was not the position earlier to the amendment. Therefore, the respondent-Unit was eligible for the central excise duty exemption benefit under the aforesaid Notification No. 56 only from the date of amendment vide Notification No. 79 when 'SIDCO Industrial Complex, Bari Brahmana' is included and not prior to that. 12. Mr. Magoo then submits that on scrutiny of the certificate furnished by the respondent-unit, it was noticed that it was shown falling under Khasra No. 394 in the area of Kartholi and this Khasra was mentioned under area of 'EPIP Kartholi, Bari Brahmana' in the list of Khasra under head 2(1 )(C) (2) of Annexure-II to Notification No. 56 and adjudicating authority on examination of location of unit found it to be located in Lane No. 4, SIDCO Industrial Complex, Bari Brahmana, Jammu. Therefore, the view taken by the Appellate Tribunal is contrary to the facts. 13. According to the learned counsel, Industrial area Bari Brahmana, Jammu is spread over as 'SIDCO Industrial Complex, Bari Brahmana, village Kartholi, village Birpur and EPIP Kartholi'. Therefore, the view taken by the Appellate Tribunal is contrary to the facts. 13. According to the learned counsel, Industrial area Bari Brahmana, Jammu is spread over as 'SIDCO Industrial Complex, Bari Brahmana, village Kartholi, village Birpur and EPIP Kartholi'. Therefore, the name of EPIP Kartholi, Bari Brahmana has to be taken as EPIP Kartholi situated in Bari Brahmana as mentioned in Annexure-II of Notification No. 56. 14. Mr. Magoo lastly contends that even otherwise Notification No. 79 amending earlier Notification No. 56, which according to him, is not otherwise clarificatory in nature has been issued after one year of the issuance of Notification No. 56, therefore, cannot be given retrospective effect inasmuch as the earlier Notification No. 56 was issued on 14.11.2002, whereas Notification No. 79 was issued on 22.12.2003. The amending Notification is issued under Sub-section 2A of Section 5A of 'the Act'. This amendment by inserting Section 2A has been made with a purpose, so that if the Central Government considers it necessary or expedient for the purpose of clarifying the scope or applicability of any earlier Notification issued under Sub-section (1) or Sub-section (2), the explanation, so made by amending Notification, which should form part of the earlier notification, it is to be made within one year of the issuance of earlier Notification and not thereafter. The respondent unit, which did not fall under proper industrial area where Khasra No. 394 was notified prior to the issuance of amending Notification No. 79, thus, cannot be allowed to avail the tax exemption benefit retrospectively. Therefore, the order passed by the learned Appellate Tribunal quashing the order dated 25.04.2005 of Commissioner Central Excise and Customs is not in consonance with amended Notification No. 79, as such, deserves to be quashed in the instant appeal. 15. Per Contra, Mr. Malik submits that the intention of the basic Notification No. 56 was to grant benefit of exemption to the respondent-unit located within EPIP, which is an area village Kartholi. It is for that purpose such Khasra numbers have been mentioned which fall within EPIP. He submits that EPIP is a small area carved out of village Kartholi, whereas Khasra numbers mentioned under the name of Industrial area EPIP Kartholi, Bari Brahmana in the notification which includes Khasra No. 394 indicates that apart from EPIP Kartholi, Khasra numbers which fall in Industrial area Bari Brahmana are in village Kartholi. He submits that EPIP is a small area carved out of village Kartholi, whereas Khasra numbers mentioned under the name of Industrial area EPIP Kartholi, Bari Brahmana in the notification which includes Khasra No. 394 indicates that apart from EPIP Kartholi, Khasra numbers which fall in Industrial area Bari Brahmana are in village Kartholi. By mentioning the Khasra numbers of village Kartholi, which may or may not fall within the area called EPIP under heading EPIP Kartholi, the intention is to give benefit to all these Khasra numbers. Therefore, Notification No. 56 does not by mentioning EPIP Kartholi intends to lay down industrial units located within EPIP alone are entitled to exemption. Had this been the intention, there would have no Khasra number which falls within Kartholi but outside EPIP. 16. Learned counsel further submits that the respondent-Unit is set up on the piece of land bearing Khasra No. 394 of village Kartholi, forming part of SIDCO Industrial area. Khasra No. 394, which is appearing against EPIP Kartholi, Bari Brahmana, Jarnmu in annexure-11 of Notification No. 56 indicates only Khasra numbers of the Unit, as there can never be two Khasra numbers having identical number (394) in village. In fact, there is only one Khasra Number 394, which exists in the record of Directorate of Industries, J&K, and there is no other Khasra No. 394. 17. Strengthening his arguments, Mr. Malik further submits that since there was a confusion on this aspect, may by on account of some clerical mistake, Ministry of Finance by way of issuance of Notification No. 79 by carrying out necessary amendment in the earlier Notification clarified the position by reiterating the fact that Khasra No. 394 mentioned in Annexure-11 to the original Notification No. 56 under heading 2J AMMU PROVINCE' in sub heading (I) DISTRICT JAMMU under heading (C) existing location run by "DIRECTORATE OF INDUSTRIES AND COMMERCE", against S.No.2 pertains to 'SIDCO Industrial Complex, Bari Brahmana' only, where the respondent-Unit is set up. Therefore, amending notification has not changed the ground reality, so far as location of the respondent-unit is concerned. Basic complexion is not changed at all, as the amending notification does not add or delete any Khasra number. In fact, it is clarificatory in nature but the intent and purport is the same. Therefore, amending notification has not changed the ground reality, so far as location of the respondent-unit is concerned. Basic complexion is not changed at all, as the amending notification does not add or delete any Khasra number. In fact, it is clarificatory in nature but the intent and purport is the same. The respondent-unit is, thus, entitled to the benefit of excise duty exemption retrospectively, from the date Notification No. 56 came to be issued. Therefore, the order passed by the Appellate Tribunal does not suffer any infirmity and deserves to be confirmed, Mr. Malik so contends. 18. It is not disputed that with a view to fillip the Industrialization process in the State of Jammu and Kashmir, Government of India had announced a package of incentives by way of exemption from the central excise duty. In order to implement the initiative taken by the Central Government, exemption Notification No. 56 came to be issued. Encouraged by the above policy, certain entrepreneurs thought of establishing their units in the area specified by the State Government for industrial use. One such industrial area developed by the Directorate of Industries and Commerce located at village Kartholi. Khasra No. 394, on which the respondent-unit is situated, has been notified under 'E.P.I.P., Kartholi Bari Brahmana' in Notification No. 56, as indicated in Annexure-II appended to aforesaid Notification No. 56 relating to Jammu Province. For reference, it is extracted from the Annexure. It reads:- 2. E.P.I.P. 300, 300/1, 313, 321, 321/1, 322, Samba Bari Kartholi Bari 323 Brahamana Brahamana 311, 315, 315-min 316 to 350, 351, 355, 358, 360, 365, 365-min, 363-min, 366, 366/1, 367, 367/1, 368, 369/1, 369-min, 371 to 379, 379/1, 380 to 398, 400 to 403, 404, 404-min, 405, 407 to 409, 452, 454, 454/1, 19. The Central Excise Authorities denied the benefit of exemption to respondent-unit on the ground that the aforesaid entry 'EPIP Kartholi Bari Brahmana' did not specifically covered 'SIDCO Industrial Complex, Bari Brahmana' or village 'Kartholi'. Since the respondent-unit and one another such industrial unit was denied the benefit of tax exemption, they represented to Industries and Commerce Department, Jammu and Kashmir State. Since the respondent-unit and one another such industrial unit was denied the benefit of tax exemption, they represented to Industries and Commerce Department, Jammu and Kashmir State. The matter was taken up by the State Government with the Central Government (Ministry of Finance, Department of Revenue) to amend earlier Notification No. 56 and substitute the entry 'EPIP Kartholi Bari Brahmana' with 'SIDCO Industrial Complex, Bari Brahmana' or 'EPIP Kartholi' or village 'Kartholi' or village 'Birpur'. This is how the amendment vide Notification No. 79/2003-CE dated 22.12.2003 came to be issued. The said Notification reads:- "In exercise of the powers conferred by sub-section (1) of Section 5A of the Central Excise Act, 1944 (1 of 1944), read with sub-section (3) of Section 3 of the Additional Duties of Excise (Goods of Special Importance) Act, 1957 (58 of 1957) and sub-section (3) of section 3 of the Additional Duties of Excise (Textiles and Textile Articles) Act, 1978 (40 of 1978), the Central Government, being satisfied that it is necessary in the public interest so to do, hereby makes the following further amendment in the notification of the Government of India in the erstwhile Ministry of Finance and Company Affairs (Department of Revenue) No. 56/2002-Central Excise, dated the 14th November, 2002, namely:- In the said notification, in Annexure-II, under heading 2. JAMMU PROVINCE', in sub-heading (I)DISTRICT JAMMU', under heading '(Q Existing location run by Directorate of Industries and Commerce', in the Table, against S.No.2, in column 'Name of the Industrial Area', for the entry "E.P.I.P. Kartholi Bari Brahamana", the entry "SIDCO Industrial Complex Bari Brahmana or E.P.I.P. Kartholi or village Kartholi or village Birpur", shall be substituted." 20. Despite amendment made vide aforesaid Notification No. 79, the respondent-unit was not being benefited of tax exemption, a request was once again made to the Industries and Commerce Department, Jammu and Kashmir State to take up the matter with the Ministry of Finance, Department of Revenue to give retrospective effect to the amendment brought out by Notification No. 79. Considering the request of the respondent-unit and another unit facing the same problem, Principal Secretary to Government, Industries and Commerce Department of State took up the matter with the Ministry of Finance, Department of Revenue explaining the entire locational position of the respondent-unit set up in a particular area, made a request to the Ministry of Finance, Department of Revenue to issue necessary clarification to give retrospective effect to the amendment notified vide Notification No. 79. 21. All what is said hereinabove is borne out from a request letter dated 23.02.2004 (Annexure-R7), written by Principal Secretary to Government, Industries and Commerce Department, J&K State to the Joint Secretary, (Ministry of Finance, Department of Revenue), which document was taken on record by allowing application bearing CMP No. 2/2009 vide order dated 02.12.2009. Admittedly, this letter was also placed before the learned Appellate Tribunal. 22. Since the aforesaid letter (Annexure-R7) refers to the location, where the respondent-unit is set up, we have also felt the necessity of reproducing the relevant para for better appreciation of the controversy, at least on factual aspect. It reads:- "4. The request of the units has been examined. It is a fact that SIDCO Industrial Complex, Bart Brahmana consists of two main villages Kartholi & Birpur. Again both the industrial estates of SIDCO Industrial Complex, Bari Brahmana & EPIP Kartholi are covered by the notification No. 56/2002 for the exemption of excise duty and also both are developed by the State's Directorate of Industries and Commerce for setting up of Industries to avail of the incentives under the package announced by the Union Government. It has all along been the intention of the J&K Government to enable various sectors of industry to set up units in these areas including the land wherein the above mentioned units have been set up Khasra Numbers of both these units are very much included in the original notification to give benefit of excise exemption. However, somehow it happened that such Khasra numbers alongwith some other Khasra numbers of SIDCO Industrial Complex, Bari Brahmana & Village Kartholi were wrongly classified under the sub heading 'EPIP Kartholi Bari Brahamana'. The notification No. 79/2003 dt 22.12.2003 has been issued on our request only to remove this anomaly and to give correct and factual meaning to already notified Khasara numbers." 23. The notification No. 79/2003 dt 22.12.2003 has been issued on our request only to remove this anomaly and to give correct and factual meaning to already notified Khasara numbers." 23. What one gathers from the aforesaid narrated facts is that even the Industries and Commerce Department, Jammu and Kashmir State has also been requesting the Ministry of Finance, Department of Revenue to give retrospective effect to the amendment notified vide Notification No. 79 to the respondent-unit and another unit reference thereto made in Annexure-R7 so that these units could get their excise duties refunds relating to the period of said notification. 24. Precisely in the aforesaid factual backdrop, the question of law referred to hereinabove needs to be answered. 25. Main stress of Mr. Magoo, learned counsel for the appellant, is that Notification No. 79 amending the ba?;c Notification No. 56 shall be applicable with effect from 22.12.2003 only, as the location of the respondent-unit has been incorporated in clause-2 with effect from 22.12.2003. Therefore, the respondent-unit is eligible for exemption only from this date and not pursuant to Notification No. 56 effective from 14.11.2002. 26. We are not in agreement with the submission advanced by Mr. Magoo. 27. One of the principles of interpretation of Statutes is that the legislature does not use unnecessary words/figures. If the exemption notification is to be interpreted in the way, the appellant wants it to be interpreted then the Khasra number could be interpreted to be a non-existing Khasra number regarding which the ' exemption was initially granted vide Notification No. 56. Therefore, only way of giving correct interpretation to the Notification would be to read Khasra number at a place where it was actually meant to be read. Since there was some confusion before the authorities below, as to whether the respondent-unit or other such like unit was covered by initial exemption Notification No. 56 or not, inasmuch as, the field survey (khasra No.) where the unit of the respondent was set up is actually mentioned in the exemption notification or by mistake, it was mentioned in different industrial area where there was no suci u i, M survey (Khasra No.), on this aspect only, Industries and Commerce Department, Jammu and Kashmir, sought clarification which aspect was subsequently corrected by Government of India by issuance of amended Notification No. 79 dated 22.12.2003. Therefore, in our considered view, amended Notification is clarificatory in nature and has to be read in continuity with earlier Notification No. 56 effective from 14.11.2002. 28. We clarify it further, if one reads the amended Notification No. 79, in Annexure-II, under heading 2 JAMMU PROVINCE', in sub-heading (I) DISTRICT JAMMU', under heading '(C) Existing location in the Table, against S.No.2, in column 'Name of the Industrial Area', for the entry "E.P.I.P. Kartholi Ban Braham-ana", the entry 'SIDCO Industrial Complex Bari Brahmana' or 'E.P.I.P. Kartholi' or village 'Kartholi' or village 'Birpur', has been substituted. 29. Much stress has been laid by Mr. Magoo that Notification No. 79 has been passed after one year of earlier Notification No. 56, which was made effective from 14.11.2002 whereas the amending notification was made effective from 22.12.2002. Therefore, in terms of Sub-section 2A of Section 5A of the 'Act', it can have the retrospective effect only, had it been passed within a period of one year of the issuance of earlier notification and not otherwise. 30. The arguments do not appeal to us at all. 31. Sub-section 2A was inserted in Section 5A of 'the Act' by Act 20 of 2002 with effect from 11.05.2002. It reads:- " (2A) The Central Government may, if it considers it necessary or expedient so to do for the purpose of clarifying the scope or applicability of any notification issued under sub-section (1) or order issued under sub-section (2) insert an explanation in such notification or order, as the case may be, by notification in the Official Gazette at any time within one year of issue of the notification under sub-section (1) or order under sub-section (2), and every such explanation shall have effect as if it had always been the part of the first such notification or order, as the case may be". 32. Undoubtedly, Notification No. 56 is issued under Sub-section (1) of Section 5A of the Act. But what needs to be appreciated in the case on hand is, whether subsequent Notification No. 79, which is otherwise not issued under Sub-section 2A of the Act as is clear from the wording of the notification itself can be said to be a notification for the purposes of clarifying the scope or applicability of the earlier notification or it is just substitution of the word without changing the basic structure of the earlier notification. This aspect again needs to be appreciated vis-a-vis the location, where respondent-unit is set up in the background of the facts of the present case. 33. Admittedly, the site where the respondent-unit was established is not changed at all. The controversy was with regard to Khasra No. 394 falling under heading 2 JAMMU PROVINCE', in Annexure-H appended to earlier Notification No. 56. In fact, 'SIDCO Industrial Complex, Bart Brahmana' consists of two main villages, villages Kartholi and Birpur. Both the Industrial Estates of 'SIDCO Industrial Complex, Bari Brahmana' and 'E.P.I.P. Kartholi' are covered by Notification No. 56 for the purpose of exemption of excise duty. However, it so happened that some khasra numbers of SIDCO Industrial Complex, Ban Brahmana and village Kartholi were wrongly classified under the sub heading 'E.P.I.P. Kartholi, Bari Brahmana'. Notification No. 79 was issued only to remove this anomaly and to give correct and factual meaning to the already notified Khasra numbers. 34. Viewing the present case in the aforesaid factual backdrop, it cannot be said that Notification No. 79, which is effective from 22.12.2003 is a notification falling within the ambit of Sub-section 2A of Section 5A of the Act, clarifying the scope or applicability of the earlier notification issued under sub-section (1) of Section 5A of the Act. At the cost of repetition, the amending notification has not changed the ground reality, as it does not add or delete any Khasra number in it. Therefore, it is clarificatory in nature and not explanatory, as the intent and object of the basic Notification No. 56 is not changed at all. In our considered view, it will not amount to insert an explanation to the earlier notification falling within the ambit of Sub-section 2A of Section 5A of the Act, covering the stipulated time frame of one year only. Therefore, the plea raised by Mr. Magoo in the regard, in our view, will not be available to him, so as to give prospective effect for the purpose of tax duty exemption. 35. In case titled 'Government of India v. Indian Tobacco Association' reported as 2005 (187) E.L.T. 162 (S.C.)' their lordships while dealing with the interpretation of statutes vis-a-vis the exemption/beneficent notification, so as to extend the benefit retrospectively or prospectively, observed in Para Nos. 10 to 15 as under: - "10. 35. In case titled 'Government of India v. Indian Tobacco Association' reported as 2005 (187) E.L.T. 162 (S.C.)' their lordships while dealing with the interpretation of statutes vis-a-vis the exemption/beneficent notification, so as to extend the benefit retrospectively or prospectively, observed in Para Nos. 10 to 15 as under: - "10. An exemption notification it is trite, must be construed having regard to the object and purport which the same seeks to achieve. 11. It is also well-settled that an expression used in a statute should be given its ordinary meaning unless it leads to an anomalous or absurd situation. 12. In Mahaan Dairies (supra), a Division Bench of this Court observed: "8, It is settled law that in order to claim benefit of a Notification a party must strictly, comply with the terms of the Notification. If on wordings of the Notification the benefit is not available then by stretching the words of the Notification or by adding words to the Notification benefit cannot be conferred..." 13. A similar view has been expressed by a Division Bench of this Court in Tata Iron & Steel Co. Ltd. v. State of Jharkhand and Others [ (2005) 4 SCC 272 ], in which one of us was a party stating: "42. Eligibility clause, it is well settled, in relation to exemption notification must be given a strict meaning." 14. However, the question which arises for consideration in this case is as to what would be the effect of the subsequent notification. 15. The word "substitute" ordinarily would mean "to put (one) in place of another"; or "to replace". In Black's Law Dictionary,, Fifth Edition, at page 1281, the word "substitute" has been defined to mean "To put in the place of another person or thing", or "to exchange". In Collins English Dictionary, the word "substitute" has been defined to mean "to serve or cause to serve in place of another person or thing"; "to replace (an atom or group in a molecule) with (another atom or group)"; or "a person or thing that serves in place of another, such as a player in a game who takes the place of an injured colleague". 36. 36. In the aforesaid case also, the Central Government intended to extend the benefit to the respondent-unit therein with prospective effect only, which contention was repelled by the Apex Court observing that by reason of the amended notification, the Central Government only intended to rectify a mistake and, thus, the same will have retrospective effect and retroactive operation. While dealing with the said issue, their lordships observed as under:- "26. We are not oblivious of the fact that in certain situations, the Court having regard to the purport and object sought to be achieved by the legislature may construe the word "substitution" as an "amendment" having a prospective effect but such a question does not arise in the instant case. 27. There is another aspect of the matter which may not be lost sight of. Where a statute is passed for the purpose of supplying an obvious omission in a former statute, the subsequent statue relates back at the time when the prior Act was passed". 37. The ratio of Indian Tobacco Association's case (Supra) is applicable to the facts of the case on hand on all fours. 38. As a sequel of the aforesaid discussion, the question of law formulated as referred to hereinabove in para 2 is answered in affirmative. 39. Resultantly, we uphold the order of learned Appellate Tribunal dated 18.12.2006 and dismissed the appeal on hand.