As per the case facts the appellant a glass manufacturer challenged the taxation of tinted glass sheets The High Court had upheld the tax The question arose whether tinted glass ... sheets are liable to be taxed as goods or wares made of glass under a specific notification entry or as an unclassified item Finally the Supreme Court found no vagueness in the notification dated stating that Entry No clearly brings all goods and wares made of glass within the tax's scope not including plain glass panes The Court emphasized that exemptions being statutory creations must be construed strictly and any vagueness in an exemption clause benefits the revenue Thus the Supreme Court saw no reason to interfere with the impugned judgments and dismissed the appeals upholding the notice for reassessment