nat the phrase support services and the phraseminingof petroleumcrudeor natural gas or both have been connected with the word "to",whichhasbeeninterpretedandelaboratedby the Appellant under their submissions made hereinabove.Inthisregard,theAppellanthave nterpreted that the meaning of the term to"should beconstruedas"towards"or Concerned". Here also, we tend to agree with the interpretationandmeaningdrawnin respect of the word "to" on the basis of the dictionary meaning of the said word. Now, arter having drawn the interpretation and meaning of the aforesaid words and phrases, we PrOCeed to interpret the scope of the pertinent entry, i.e., entry under SI. No. 24(i1) of the Kate Notification. On bare perusal of the said entry and on application of the fundamental prineiple of literal rule of interpretation, it is observed that the said entry covers only Such activities or services which are used directly in the mining operations as understood by the aforesaid dictionary meaning of the term "mining" which essentially entails the excavation of the land or sea to extract the valuable substances therefrom. In this regard, we would also like to refer to the explanatory note to the scheme of classification of services which inter alia indicates the scope and coverage of the pertinent entry by illustrating certain activities which are to be included under the specific Chapter Heading, group or service code. In the context of the case, the relevant service code under the Chapter Heading 9986, having descriptionas "Support services to agriculture, hunting, forestry, fishing, mining and utilities",is 998621 which bears the description "Support services to oil and gas extraction", under which the Appellant intends to classify their services. The relevant extracts of the said explanatory note is being reproduced hereinunder:
