JUDGMENT : The petitioner is aggrieved with the exemption order passed at Exhibit P11; more so because of the denial of exemption to the major portion of the building. 2. Exhibit P11 indicates that the petitioner has a three storeyed building, of which the Ground Floor comprises of a workshop, spare parts room, office, parking area and washing area. The First Floor has a showroom and has facility for after sale service. The Second Floor is fully dedicated for after sale service. The Government in Exhibit P11 noticed that the area having an extent of 202.92 square meter of the Ground Floor has already been granted exemption by the Government itself as early as in July, 2012. However, the balance portion with respect to the Ground Floor was declined exemption which, the petitioner submits, has to be included in the exemption for reason of the spare parts room, office, parking area and washing area being ancillary activities of the workshop. This Court is inclined to accept the above said contention. 3. However, with respect to the First and Second Floors, the Government had declined exemption for reason of the activity being principally of sale of vehicle and workshop area is being used for after sale service. A learned Single Judge of this Court in K.V.R. Auto Cars (P) Ltd. v. State of Kerala [2010 (3) KLT 26], in a similar circumstance, held that the workshop running in such premises would be included in a "factory" as defined under Section 2(m) of the Factories Act, 1948 [for brevity "Factories Act"]. The petitioner also has a 'factory' licence for the workshop which is carried on in the Ground Floor. This Court in 2010 (3) KLT 26, however, has not considered the issue as to whether workshop can be considered to be the principal activity carried on when there is existing in the very same building a showroom for sale of vehicles and an after sale service centre. The exemption as granted by the Kerala Building Tax Act, 1975 [for brevity "Building Tax Act"] is for buildings used principally for religious, charitable or educational purposes or as factories or workshops. The exemption as granted by the Kerala Building Tax Act, 1975 [for brevity "Building Tax Act"] is for buildings used principally for religious, charitable or educational purposes or as factories or workshops. Hence, the determinative factor would be the principal use of the building and when there is a showroom for display and sale of the vehicles and facility for after sales, the principal use would be of sale and display of vehicles, which do not come under the exemption as has been permitted by sub-clause (b) of sub-section (1) of Section 3 of the Building Tax Act. 4. 2010 (3) KLT 26 is binding for the proposition that the repair of cars carried on would qualify and be covered under the definition of workshop and in the circumstance of a factory license issued would also qualify as a factory even going by the definition of a 'factory' under the Factories Act, 1948. After holding so this Court remanded the issue to be considered by the Government as to whether the operations carried on in the premises would come within the definition of a factory. Even then there should be further examination of the principal use to which the premises is used. The principal use cannot be the use to which the maximum plinth area is put to; in which event the exemption clause would have employed different words. 5. Exemption it is trite has to be strictly interpreted and when a subject is found to come within the exemption then the same has to be granted full play as has been held in Union of India Vs. Wood Papers Ltd. [ (1990) 4 SCC 256 ]. Paragraph 4 of the said decision is relevant and hence extracted here: "4. Entitlement of exemption depends on construction of the expression "any factory commencing production" used in the Table extracted above. Literally exemption is freedom from liability, tax or duty. Fiscally it may assume varying shapes, specially, in a growing economy. For instance tax holiday to new units, concessional rate of tax to goods or persons for limited period or with the specific objective etc. That is why its construction, unlike charging provision, has to be tested on different touchstone. Literally exemption is freedom from liability, tax or duty. Fiscally it may assume varying shapes, specially, in a growing economy. For instance tax holiday to new units, concessional rate of tax to goods or persons for limited period or with the specific objective etc. That is why its construction, unlike charging provision, has to be tested on different touchstone. In fact an exemption provision is like an exception and on normal principle of construction or interpretation of statutes it is construed strictly either because of legislative intention or on economic justification of inequitable burden or progressive approach of fiscal provisions intended to augment State revenue. But once exception or exemption becomes applicable no rule or principle requires it to be construed strictly. Truly speaking liberal and strict construction of an exemption provision are to be invoked at different stages of interpreting it. When the question is whether a subject falls in the notification or in the exemption clause then it being in nature of exception is to be construed strictly and against the subject but once ambiguity or doubt about applicability is lifted and the subject falls in the notification then full play should be given to it and it calls for a wider and liberal construction. Therefore, the first exercise that has to be undertaken is if the production of packing and wrapping material in the factory as it existed prior to 1964 is covered in the notification". (Underlining supplied here) 6. It is to be noticed that in 2010 (3) KLT 26 the issue as to whether the building is principally used as a factory or a workshop was directed to be considered by the Government. The said issue has been considered by the government and answered in the present case by the impugned order. There is in existence a dealership for which an office and a showroom with display of cars is maintained by the petitioner in the building. Hence the principal use to which the building is put to is the dealership and after sales service is only an ancillary activity carried on by the petitioner as mandated by the manufacturer. In such circumstance, this Court does not find any reason to interfere with the order declining exemption. Writ petition would stand dismissed. No costs.