Based on the provided legal document, here are the key points regarding the interpretation of exemption notifications in tax statutes:

• Strict Interpretation Rule: Exemption notifications must be interpreted strictly. The burden of proving that a case falls within the parameters of an exemption clause or notification lies entirely on the assessee. (!) (!) (!) (!) (!) (!) (!)
• Benefit of Ambiguity: When there is ambiguity in an exemption notification subject to strict interpretation, the benefit of such ambiguity cannot be claimed by the subject/assessee; it must be interpreted in favour of the Revenue/State. (!) (!) (!) (!) (!) (!) (!)
• Overruling Precedent: The ratio established in Sun Export Corporation, Bombay v. Collector of Customs, Bombay (1997) 6 SCC 564, which held that ambiguity in exemption notifications should be interpreted in favour of the assessee, is incorrect and has been overruled. Consequently, all decisions relying on that view are also overruled. (!) (!) (!) (!) (!) (!) (!)
• Distinction from Charging Provisions: While ambiguity in a charging provision (tax liability statute) benefits the subject/assessee, ambiguity in an exemption notification benefits the Revenue. This distinction arises because exemptions increase the burden on other taxpayers and are exceptions to the general rule of taxation. (!) (!) (!) (!) (!) (!) (!)
• Two-Stage Construction: There is a distinction between the stage of finding eligibility and the stage of applying the exemption. The eligibility criteria (whether the subject falls within the notification) must be strictly construed. However, once eligibility is established and ambiguity is resolved, the application of the exemption may be construed liberally. (!) (!) (!) (!) (!)
• Compliance Requirements: A person claiming exemption must comply with mandatory requirements of the notification. The doctrine of substantial compliance applies only to directory conditions, not to mandatory prerequisites that are essential to the object of the statute. (!) (!) (!) (!) (!)
• Legislative Intent vs. Plain Language: In taxing statutes, including exemption clauses, the court must look at the clear meaning of the words. There is no room for intendment, presumption, or equitable construction. If the Legislature fails to express itself clearly, the taxpayer escapes liability. (!) (!) (!) (!) (!) (!) (!) (!)