Wheat excluded from "millets" under sales tax schedule, so single-point purchase tax benefit was denied.

Wheat was held not to fall within the expression "millets" in Schedule III of the Andhra Pradesh General Sales Tax Act, 1957, because the term was construed in its ordinary and accepted commercial sense, where dictionary usage and common understanding treat wheat as distinct from millets. Expert material also did not place wheat within the millet category. As a result, the single-point purchase tax benefit under section 5(3) could not be extended to wheat, and wheat remained liable to multiple-point tax.

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Issues: Whether wheat falls within the expression "millets" in Schedule III of the Andhra Pradesh General Sales Tax Act, 1957, so as to attract single point purchase tax under section 5(3).

Analysis: The expression "millets" was construed in its ordinary and accepted commercial sense. The Court relied on dictionary meanings and common usage, which showed that millets are distinct from wheat. Wheat was found not to answer the description of millet in the statutory schedule, and the commodity list in the expert material also did not include wheat among millets. The benefit of single point taxation under Schedule III therefore could not be extended to wheat.

Conclusion: Wheat is not included in "millets" for purposes of Schedule III, and it remains liable to multiple point tax. The revision was therefore decided against the assessee.

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