JUDGMENT Hon’ble Yashwant Varma, J.—Heard Shri Rakesh Ranjan Agrawal, learned senior counsel assisted by Shri Suyash Agarwal for the revisionist and Shri A.C. Tripathi, learned standing counsel who appears for the respondents. 2. This revision calls in question an order of the Tribunal dated 13 February 2007 upholding the decision of the authorities denying the assessee the benefits of an exemption notification dated 27 February 1997. 3. The assessee is stated to be engaged in the manufacture of stationery material including exercise books and registers from handmade paper. The assessee was also found eligible for the grant of credit facilities by the U.P. Khadi Gram Udyog Board [“Board”]. Its case was that it was purchasing handmade paper from the Board and using the same for the purposes of manufacturing exercise books and registers. It also admittedly imported mill made paper during the assessment year in question for the purposes of manufacturing stationery articles and there was on record a clear bifurcation between the quantity of material in the shape of mill made paper which was imported as well as handmade paper which was utilized by the assessee and procured from the Board. The authorities below proceeded to deny the assessee the benefit of the exemption notification holding that admittedly it had in the assessment year also imported mill made paper. This in the considered view of the Court was clearly unsustainable since admittedly there existed on record material clearly establishing and evidencing a bifurcation of turnover of stationary items manufactured from mill made paper and handmade paper. This line of reasoning has also not been accepted by the Tribunal. 4. It has, however, proceeded to take completely a different view and has proceeded to hold that the assessee which was engaged in the manufacture of exercise books and registers would not be entitled to exemption since these articles did not stand encompassed in the notification. 5. The english translation of the relevant clause of the exemption notification which stands reproduced in the assessment order and on which there is no dispute inter partes reads thus : “Stationery material made from hand made paper/board such as file cover, file board, cudak, drawing paper, invitation cards, greeting cards and papier mache.” 6. 5. The english translation of the relevant clause of the exemption notification which stands reproduced in the assessment order and on which there is no dispute inter partes reads thus : “Stationery material made from hand made paper/board such as file cover, file board, cudak, drawing paper, invitation cards, greeting cards and papier mache.” 6. As would be evident from a perusal of the relevant clause, an assessee claiming benefits under the said notification was essentially required to establish that he was engaged in the manufacture of “stationery material” which was “made from handmade paper/board”. The clause then proceeded to amplify by way of illustration the various articles manufactured from handmade paper/board such as file cover, file board, cudak, drawing paper, invitation cards, greeting cards etc which would be entitled to be viewed as falling within the scope of the exemption. The description of the type or genre of commodities which would be covered was prefaced by the use of the phrase “such as”. 7. The relevant clause when it employed the phrase “such as” could not have been interpreted as laying down an exhaustive list of articles which alone would merit exemption. The use of the phrase is clearly indicative of the intent being of the articles mentioned thereafter to be by way of illustration. When the authority employed the phrase “such as” it was a clear expression of intent to mention just a few articles by way of illustration. The list which followed thereafter was not exhaustive. Although this principle is a well-settled rule of interpretation, it would be apposite to refer to only the following observations as they appear in two decisions of the Supreme Court in support of the conclusions recorded above. 8. In Royal Hatcheries [P] Ltd. v. State of A.P., 1994 Supp. (1) SCC 429, the Supreme Court observed : 5. Having regard to the relevance of the language employed in Rule 5(2)(xxvi), it would be appropriate to set out the same over again here. It reads : “Livestock, that is to say, all domestic animals such as, oxen, bulls, cows, buffaloes, goats, sheep, horses etc.” The clause opens with the word, ‘’livestock’, but it does not stop there. Having regard to the relevance of the language employed in Rule 5(2)(xxvi), it would be appropriate to set out the same over again here. It reads : “Livestock, that is to say, all domestic animals such as, oxen, bulls, cows, buffaloes, goats, sheep, horses etc.” The clause opens with the word, ‘’livestock’, but it does not stop there. Had it stopped there, there could be no doubt that day-old chicks or for that matter, older chicks and chicken would have certainly fallen within the ambit of the expression ‘’livestock’ and would have been taxable at purchase point. But the clause proceeds further and restricts the ambit of the expression “livestock” to domestic animals referred to therein. That is the effect of the words “that is to say”. The meaning and purport of the words “that is to say” is explained by this Court in Rajasthan Roller Flour Mills Assn. v. State of Rajasthan [1994 Supp (1) SCC 413 : JT (1993) 5 SC 138]. They are words of limitation. In other words because of the use of the said words, the livestock contemplated by the said clause becomes confined to the domestic animals referred to in the said clause. ‘’Livestock’ is, ordinarily speaking, not confined to domestic animals. As held in Peterborough Royal Foxhound Show Society v. IRC [20 Tax Cases 249 : (1936) 1 All ER 813] the word ‘’livestock’ takes in ‘’animals’ of any description. But the rule-making authority chose to limit the meaning of ‘’livestock’ in the said clause only to domestic animals mentioned therein. Yet again, the clause does not stop with the words “all domestic animals”. It proceeds further and goes on to illustrate the meaning of the expression “all domestic animals” by mentioning some of them, namely oxen, bulls, cows, buffaloes, goats, sheep and horses and then ends with the word “etc.”. This could not have been without a purpose. It could only be to indicate the type of domestic animals the rule-making authority had in mind. Why did the rule-making authority not mention a single bird, while mentioning so many animals? It is true, the words “such as” indicate that what are mentioned thereafter are only illustrative and not exhaustive. This could not have been without a purpose. It could only be to indicate the type of domestic animals the rule-making authority had in mind. Why did the rule-making authority not mention a single bird, while mentioning so many animals? It is true, the words “such as” indicate that what are mentioned thereafter are only illustrative and not exhaustive. The clause also ends with the word “etc.”, which does mean that some more domestic animals in addition to those specifically mentioned therein are also included within the meaning the words “all domestic animals”. But the question still remains, whether day-old chicks were contemplated as included within the clause? In other words, whether chicks can be called ‘’domestic animals’ so as to fall within the purview of the said clause?” (emphasis supplied) 9. Again in Sanboina Satyanarayana v. Government of A.P., (2003) 10 SCC 78 , the Supreme Court held : “8. Clause (iv) of para (3) of the Government order dated 25-1-2000 specifically stated that prisoners convicted for “crimes against women such as Sections 376 and 354 IPC while being sentenced to imprisonment for life”, will fall outside the scheme for remission granted under the said GO. When the clause noticed above, in the latter portion referred to two of the provisions of IPC, after the words “such as”, it was more by way of illustration of the excepted category of offences relating to crimes against women in general and not with an intention to be exhaustive of the same and to merely confine the words “crimes against women” to only those convicts for crime against women under Sections 376 and 354 IPC. Acceptance of any such plea would amount to not only doing violence to the language of the order of the Governor but also rewriting the same and that too in utter disregard of the very intention, a laudable one in larger and greater public interest.....” (emphasis supplied) 10. In light of the above principles which must govern the issue raised, it is evident that the description of various commodities was only illustrative and not an exhaustive list of articles which alone would qualify for exemption. In light of the above principles which must govern the issue raised, it is evident that the description of various commodities was only illustrative and not an exhaustive list of articles which alone would qualify for exemption. In view of the above, this Court is of the considered opinion that the Tribunal clearly erred in refusing to accord relief to the assessee on the ground that registers and exercise books were not covered under the relevant clause of the exemption notification. 11. The view taken by the Tribunal is rendered unsustainable for yet another fundamental reason. As noted above, in order to qualify for exemption the assessee was liable to establish that it was engaged in the manufacture of stationery items from hand made paper/board. The question which therefore should have essentially been posed was whether it was in fact engaged in the manufacture of stationery items from hand made paper/board. The fact that registers and exercise books are in fact utilized for writing cannot possibly be disputed. This Court finds itself unable to appreciate why registers and exercise books would not fall within the ambit of the expression “stationery materials”. 12. P. Ramanatha Aiyar in his “Advanced Law Dictionary” defines “stationery” to mean “writing material and the like”. Similarly in the Oxford English Dictionary [Second Edition Vol. XVI], the word “stationery” has been described as “1. The articles sold by a stationer; writing materials, writing-table appurtenances”. Similarly the word “stationer” has been defined as “d. A tradesman who sells writing materials and similar articles.” 13. The above authoritative definitions of the word “stationery” leave this Court in no doubt that registers and exercise books would clearly be covered within the expression “stationery materials”. The articles manufactured by the assessee, therefore, clearly fell within the scope of the exemption notification. 14. Accordingly and for the reasons noted above, this Court find itself unable to sustain the order of the Tribunal dated 13 February 2007 which shall consequently stand set aside. The revision is accordingly allowed.