DISSENTING OPINION BY
Judge COHN JUBELIRER.I must, respectfully, dissent because I disagree with the majority’s reading of the plain language of Section 102 of the Liquor Code1 (Code), which adds non-existent requirements to the statutory language, and does not read Section 102 in context with other provisions of the Code.
First, I believe the majority errs in concluding that the plain language of Section 102 requires that a person must sell malt or brewed beverages for on-site consumption. The first clause reads: “ ‘Retail dispenser’ shall mean any person licensed to engage in the retail sale of malt or brewed beverages for consumption on the .premises of such licensee.” Section 102. The majority’s plain language reading notwithstanding, this clause contains no mandatory language such as “shall,” “must,” or “will.” The absence of such language suggests that a more accurate “plain meaning” of this phrase would be to view it as permissive — that the person licensed “may” sell such beverages for on-site consumption (but does not have to sell such beverages).
The basic, plain meaning of the word “license” is one of permission, not command: “a revocable permission to commit *179some act that would otherwise be unlawful,” Black’s Law Dictionary 931 (7th Ed. 1999); “permission to act,” Merriam-Webster Online Dictionary.2 Nothing in this definition of retail dispenser departs from that plain meaning.
The next clause of Section 102 further provides that the licensed party has the “privilege” of selling such beverages for off-site consumption, limiting the quantity that could be purchased for such consumption to no more than one hundred ninety-two fluid ounces “in a single sale to one person, to be carried from the premises by the purchaser thereof.” 47 P.S. § 1-102. “Privilege” is defined as “[a] special legal right, exemption, or immunity granted to a person or class of persons” Black’s Law Dictionary 1215 (7th Ed. 1999), and “a right or immunity granted as a peculiar benefit, advantage, or favor.” Merriam Webster Online Dictionary.3 Thus, the second clause of Section 102 essentially provides that one with a license to sell for on-site consumption also has a special privilege to sell limited quantities to a single person for off-site consumption.
Reading the two clauses together shows there is nothing in the language or the plain meaning of the terms that necessarily requires one exercising the privilege to sell for off-site consumption to also sell for on-site consumption:
“Retail dispenser” shall mean any person licensed to engage in the retail sale of malt or brewed beverages for consumption on the premises of such licensee, with the privilege of selling malt or brewed beverages in quantities not in excess of one hundred ninety-two fluid ounces in a single sale to one person, to be carried from the premises by the purchaser thereof.
47 P.S. § 1-102. The plain meaning of this language is simply, one who has permission to sell beverages for on-site consumption (by license), and may (by privilege) sell in limited quantities per person for off-site consumption. The majority, however, appears to read a “must sell for on-site consumption” requirement into the language of Section 102 that simply is not there. In doing so, I believe the majority errs in its “plain language” reading of the section.
Additionally, the majority errs by reading this section in isolation. The Code is a comprehensive statutory system with interdependent parts that must be read together to correctly discern our Legislature’s intent. These sections are very clear as to what is prohibited and required of retail dispensers. For instance, Section 442 of the Code contains several limitations and requirements a retail dispenser must meet. 47 P.S. § 4-442. For instance, subsection (a) specifically requires retail dispensers to buy all malt or brewed beverages in bulk in the matter prepared for the market, but then allows the retailer to break that bulk for on or off premises consumption.4 47 P.S. § 4-442(a). Subsection (b) of Section 442 of the Code limits the areas in which malt or brewed beverages can be sold for on-site consumption to those areas accessible at all times *180to the public. 47 P.S. § 4-442(b).5 Additional restrictions are found in other sections of the Code. For instance, Section 432(f) of the Code provides requirements for those retail dispensers choosing to sell malt or brewed beverages on Sundays. 47 P.S. 4-432(1).6 What can be drawn from these sections is that the General Assembly has been explicit in setting forth restrictions and clear in explaining them. What also can be drawn from this is that the definition section, alone, is insufficient in defining the requirements and responsibilities of the license. Neither the retail dispenser definition, nor the various sections imposing restrictions on a retail dispenser, in any way indicate that such a retail dispenser must sell for on-site consumption.7 That the statute does not clearly mandate this requirement is consistent with-the Pennsylvania Liquor Control Board’s (PLCB) analysis.
The effect of the majority’s analysis is to read into the PLCB’s licensing a requirement that the retail dispenser’s license must be used to the fullest extent. The majority does this without citation to statutory authority or precedent. The PLCB notes that it has never required any of its licensees to utilize their individual licenses and permits to the fullest extent, and it provides numerous examples.8 The PLCB’s statement seems consistent with the law — the Malt Beverages Distributors Association have not provided any authority requiring that licenses be used to the fullest extent authorized.
In sum, I respectfully believe the majority misreads the plain language of the statute, addressing this provision in iso*181lation and not in context with other provisions of the Code, and thus, reads into the language a mandatory requirement that is simply not there.9
Accordingly, I would defer to the interpretation of the PLCB, and affirm its determination in this matter.
Judge LEADBETTER and Judge LEAVITT join in this dissenting opinion.
. Act of April 12, 1951, P.L. 90, as amended, 47 P.S. § 1-102.
. Merriam-Webster Online (http://www.m-w. com/209.161.37.11/dictionary/license).
. Merriam-Webster Online (http://www.m-w. com/209.161.37.11/dictionary/privilege).
. Section 442(a) provides that:
No retail dispenser shall purchase or receive any malt or brewed beverages except in original containers as prepared for the market by the manufacturer at the place of manufacture. The retail dispenser may thereafter break the bulk upon the licensed premises and sell or dispense the same for consumption on or off the premises so licensed. ...
47 P.S. § 4-442(a) (emphasis added).
. This Section provides that:
(b) No retail dispenser shall sell any malt or brewed beverages for consumption on the licensed premises except in a room or rooms or place on the licensed premises at all times accessible to the use and accommodation of the general public, but this section shall not be interpreted to prohibit a retail dispenser from selling malt or brewed beverages in a hotel or club house in any room of such hotel or club house occupied by a bona fide registered guest or member entitled to purchase the same or to prohibit a retail dispenser from selling malt or brewed beverages in a bowling alley where the licensed premises and bowling'alley áre immediately adjacent and under the same roof.
47 P.S. § 4-442(b).
. This Section provides that:
(f) Hotel, eating places, or municipal golf course retail dispenser licensees may sell malt or brewed beverages between the hours of eleven o'clock antemeridian on Sunday and two o’clock antemeridian on Monday upon purchase of a special permit from the board at an annual fee as prescribed in section 614-A of the act of April 9, 1929 (P.L. 177, No. 175), known as "The Administrative Code of 1929,” which shall be in addition to any other license fees. This subsection shall not apply to cities of the first class.
47 P.S. § 4 — 432(f).
. If anything, the language of Section 442(a) arguably seems more supportive of retail dispensers having a choice that rests in their own discretion.
. For instance, retail licensees may sell alcohol from 7:00 a.m. to 2:00 a.m., but they are not required to be open that full span of hours. Sections 406 and 499 of the Liquor Code (Code), 47 P.S. §§ 4-406, 4-499. As another example, a licensee may obtain an amusement permit which allows various forms of entertainment on the licensed premises; however, the licensee need not provide all the types of entertainment authorized. Section 493 of the Code, 47 P.S. § 4-493(10). Additionally, the Code contains provisions for licensees that are not using their licenses at all, allowing them to keep them with the PLCB for safekeeping for up to three years. Section 474.1 of the Code, 47 P.S. § 4-474.1. It stands to reason that if one can have a license without using it at all, and there is a provision for that, one can maintain their license if the person is actually using it, although not to the fullest extent.
. I would find that, even if we give the PLCB no deference in their interpretation, the plain language of the statute clearly supports their interpretation. To the extent there is any question as to that plain language, given our remand to the PLCB presumably to benefit from their expertise, some degree of deference, however slight, should be given that interpretation. See ARIPPA v. Pennsylvania Public Utility Commission, 792 A.2d 636, 660 (Pa.Cmwlth.2002) (stating that "[n]ormally, no deference is given when an agency interprets a statute to justify its position in litigation, as in a brief filed in court.... Only when an agency is acting in its expert capacity, either issuing a regulation or acting in an adjudicative capacity, is an agency given deference in its interpretation of a statute.”) Nevertheless, as noted, I believe the PLCB's conclusion is supported, even under plenary review by this Court.