ORDER : KRISHN KUMAR LAHOTI, J. 1. This batch of appeals is directed against a common order passed in W.P. No. 4362 of 2008 (RKDF Institute of Science and others Vs. Municipal Corporation, Bhopal and others) by which several writ petitions were decided by the Writ Court, holding that the respondents who are providing technical education or professional education or vocational education, as the case may be, are exempted from payment of property tax under sub-section (c) of Section 136 of the Municipal Corporation Act, 1956 hereinafter referred to as "the Act"). This order has been assailed by the appellant on the following grounds:-- That sub-section (c) though exempts buildings and lands or portion thereof used exclusively for educational purposes but restricts the aforesaid exemption only to schools, boarding houses, hostels and libraries and except these no other institutions though may be educational, is not entitled for exemption. It is submitted that though word "include" is used in the sub-section but on reading the entire section, the exemption is restrictive in nature and not extensive. He has placed reliance, in support of his contention, on two judgments of the Apex Court namely The South Gujarat Roofing Tiles Manufacturers Association and Another Vs. The State of Gujarat and Another, AIR 1977 SC 90 and M/s. Mahalakshmi Oil Mills Vs. State of Andhra Pradesh, AIR 1989 SC 335 and submitted that this appeal may be allowed. The order, passed by the Writ Court, may be set aside. 2. Sarvashri Vivek Rusia and A.P. Shroti, learned Counsels appearing for the respondents supported the order. It was submitted by them that the provisions as contained in sub-section (c) of Section 136 is extensive in nature, though word "Schools, Boarding houses, hostels and libraries" are referred but these are by way of examples and by way of extending exemption. It is submitted by them that the order passed by the Writ Court is in accordance with the provisions as contained under sub-section (c) of Section 136, which has been enacted to extend benefits of exemption of property tax to the institutions which are providing education. 3. To appreciate the rival contentions of the parties it would be appropriate to refer some facts of the case. The respondents are the institutions providing technical, professional and vocational education in various fields. 3. To appreciate the rival contentions of the parties it would be appropriate to refer some facts of the case. The respondents are the institutions providing technical, professional and vocational education in various fields. They are owners of certain accommodation, situated within the township of Municipal Corporation, Bhopal and had claimed exemption from payment of property tax. Under sub-section (c) of Section 136 of the Act, that the respondents are not liable for payment of property tax and are exempted. 4. The aforesaid contention was not accepted by the Municipal Corporation and property tax was imposed upon the respondents. Aggrieved by the aforesaid action, respondents had filed writ petitions before this Court. Various petitions came for hearing before the Writ Court. The learned Single Judge after hearing the parties, by passing a composite order dated 22-4-2010 decided all the matters. Learned Single Judge considered the provision as contained under Sections 132(1)(a) and 136(c) of the Act and recorded a finding that the definition is inclusive in nature and includes aforesaid four categories also if the building is used for educational purposes. By holding it, the learned Single Judge has found that all the respondents were entitled for exemption from payment of property tax and accordingly allowed all the petitions. This has caused appellants to file these appeals. 5. Section 132(1)(a) of the Act is enabling provision providing imposing of the tax and Section 136(c) provides exemption, reads as under:-- 132. Taxes to be imposed under this Act.--(1) For the purpose of this Act, the Corporation shall, subject to any general or special order which the State Government may make in this behalf, imposed in the whole or in any part of the Municipal Area, the following taxes, namely:-- (a) a tax payable by the owners or building or lands situated within the city with reference to the gross annual letting value of the buildings or lands, called the property tax, subject to the provisions of Sections 135, 136 and 138. 136. Exemptions.--The property tax levied u/s 135 shall not be leviable in respect of the following properties, namely:-- (c) buildings and lands or portions thereof used exclusively for educational purposes including schools, boarding houses, hostels and libraries if such buildings and lands or portions thereof are either owned by the educational institutions concerned or have been placed at the disposal of such educational institutions without payment of any rent. Section 132 of the Act provides that tax shall be payable by the owners of the land situated within the Municipal Area for which gross annual letting value shall be relevant for the purposes of imposition of the property tax, subject to provision as contained under Sections 135, 136 and 138. Section 135 provides imposition of the property tax. The aforesaid sections provide that every Municipal Corporation is empowered to charge and levy the property tax at the rate of not less than 6% and not more than 10% of the Annual Letting Value as determined by the Corporation for each financial year. It is not in dispute that in absence of exemption as provided under sub-section (c) of Section 136 of the Act, the respondents were otherwise liable for payment of property tax but the exemption provision provide that the building and lands and portion which are used exclusively for the educational purposes including schools, boarding houses, hostels and libraries shall be exempted from payment of such tax, if such buildings and lands are either owned by the educational institution concerned or even placed at the disposal of such educational institutions without payment of any rent, such property tax shall not be leviable in respect of such properties. The only question which arises in this appeal is whether word "include" is used for the purpose of providing exemption, restrictive or extensive. It is the settled law that the definition of the word under the section may either be restrictive by its ordinary meaning or it may be extensive. [See: Commissioner of Trade Tax, U.P. and Another Vs. Kajaria Ceramics Ltd., AIR 2005 SC 2968 ]. 6. In the present case, the definition is very simple and the provision is very clear. It provides exemption to the building and lands used exclusively for educational purpose. The entire purpose of providing such exemption is to the buildings and lands used exclusively for educational purpose. The word include has been used in the provision which provides that the School, Boarding houses, hostels and libraries shall also be included for providing exemption if the buildings and lands are used exclusively for the aforesaid purposes either owned or occupied without any payment of rent. The intention of legislation is clear and from the reading of entire provision. The word include has been used in the provision which provides that the School, Boarding houses, hostels and libraries shall also be included for providing exemption if the buildings and lands are used exclusively for the aforesaid purposes either owned or occupied without any payment of rent. The intention of legislation is clear and from the reading of entire provision. It is apparent that the intention of the legislation was to extend exemption to the buildings and lands used exclusively for the educational purposes and we have to interpret the provision in that perspective. 7. From the perusal of the aforesaid provision, it is apparent that the entire definition is extensive and has to be interpreted in the manner in which it has been provided in the section. 8. In South Gujarat Roofing Tiles (supra), the Apex Court was interpreting the expression potteries industry in which the word was used includes and the Explanation to the said provision was provided thus:-- Explanation:--For the purpose of this entry potteries industry includes the manufacture of the following articles of pottery, namely:-- (a) Crockery (b) Sanitary appliances and fittings (c) Refractories (d) Jars (e) Electrical accessories (f) Hospital ware (g) Textile accessories (h) Toys (i) Glazed Tiles The aforesaid Explanation makes the provision restrictive because the aforesaid provision was applicable only in respect of 9 types of industries which were referred in the Explanation. The factual position in the present case is entirely different and the ratio of South Gujarat Roofing Tiles (supra), is not applicable in the present case. 9. The learned Single Judge has rightly interpreted the provision. When an exemption has been provided, the exemption provision has to be applied accordingly and the exemption cannot be denied and the language used in the provision must be given due weight. See Indian Farmers Fertiliser Cooperative Limited Vs. Collector of Central Excise, Ahmedabad, AIR 1996 SC 2542 . 10. In M/s. Mahalakshmi Oil Mills (supra), the Apex Court, considering the provisions of A.P. General Sales Tax and interpreting the word "tobacco", have held that the word tobacco cannot be extended to include tobacco seed, oil or cake. See Indian Farmers Fertiliser Cooperative Limited Vs. Collector of Central Excise, Ahmedabad, AIR 1996 SC 2542 . 10. In M/s. Mahalakshmi Oil Mills (supra), the Apex Court, considering the provisions of A.P. General Sales Tax and interpreting the word "tobacco", have held that the word tobacco cannot be extended to include tobacco seed, oil or cake. The Apex Court have held that tobacco seed separated from the plant, tobacco seeds, oil or cake do not fall within the expression of tobacco or any form of tobacco and in that perspective the Apex Court have held that the tobacco seeds, oil or cake do not fall within the expression of tobacco. The position in the aforesaid case was also entirely different and the ratio in M/s. Mahalakshmi Oil Mills (supra), is not applicable in the present case. 11. Learned Counsel for the appellant has also placed reliance to the judgment of the Apex Court in State of Gujarat and Others Vs. Essar Oil Limited and Another, AIR 2012 SC 1146 , and submitted that for claiming exemption, assessee has to make out a case within the four corners of an exemption and until and unless its case fall within the exemption, does not entitle for exemption. The Apex Court in Para 88 held thus:-- 88. This Court held that the principle that in case of ambiguity, a taxing statute should be construed in favour of the assessee, does not apply to the construction of an exception of an exempting provision, as the same have to be construed strictly. Further this Court also held that a person invoking an exception or an exemption provision to relieve him of the tax liability must establish clearly that he is covered by the said provision and in case of doubt or ambiguity, benefit of it must go to the State. 12. In the present case, the exemption has been provided to the buildings and lands used exclusively for educational purposes and it further provides that it shall include school, boarding houses, hostels and libraries, if such building and lands or portions there of are either owned by the educational institutions concerned or have been placed at the disposal of such educational institutions without payment of any rent. The aforesaid provision specifically provides exemption to the buildings and lands used exclusively for educational purposes but in respect of schools, boarding houses, hostels and libraries, it has been qualified that such buildings should be owned by the educational institutions concerned or should have been placed at the disposal of such educational institutions without payment of rent. 13. From the perusal of the entire provision, it is apparent that such exemption has been broadly provided to all the buildings and lands used exclusively for educational purposes and in respect of such four types of the property, the provision has been made in later part of the sub-section. If the interpretation as submitted by the appellant is accepted then the entire purpose of granting exemption shall be frustrated. In view of the aforesaid, it is apparent that the entire purpose of providing exemption is to exempt all the buildings and lands used exclusively for the educational purposes and the respondents who are owners and are using their building exclusively for educational purposes, though for technical, professional or vocational education, are entitled for exemption under the existing provision. All the appeals are found without merit and are dismissed with costs.