Popular meaning test excludes parched rice from rice under sales tax exemption entry.

Commodity terms in a sales tax entry must be construed in their ordinary commercial and popular sense. On that approach, parched rice (atukulu) is a distinct commodity from rice: rice is ordinarily cooked before consumption, while parched rice is edible without cooking and would not ordinarily be sought as rice in commerce. The Explanation protecting rice converted from paddy therefore does not extend to parched rice, so the exemption under entry 6 of Schedule III is unavailable.

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Issues: Whether parched rice (atukulu) falls within the expression "rice" in entry 6 of Schedule III of the Andhra Pradesh General Sales Tax Act, 1957, so as to attract the exemption under the Explanation read with items 5 and 6.

Analysis: The expression "rice" in a sales tax entry must be understood in its ordinary commercial and popular meaning. Rice and parched rice are distinct commodities: rice is ordinarily consumed after cooking, whereas parched rice is edible without cooking and is not what a purchaser would ordinarily ask for when seeking rice. The cited authorities on cereal, oil, and other processed goods did not assist because they turned on different statutory language and different commercial understandings. On that construction, the Explanation protecting subsequent purchase of rice converted from paddy does not extend to parched rice.

Conclusion: Parched rice is not included in "rice" for entry 6, and the exemption is not available; the finding is against the assessee.

Ratio Decidendi: Commodity expressions in a sales tax statute are to be construed in their common or popular sense, and a processed article is not included unless it is ordinarily understood in commerce as the same commodity.

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