Common parlance meaning of "miller" covers decorticating and oil millers under the sales tax entry.

The term "miller" in item 3-C of Schedule IV of the Andhra Pradesh General Sales Tax Act, 1957 was construed in its ordinary and popular sense because it was not defined in the Act. Applying the common parlance approach, the HC held that "mill" is not confined to machinery producing a new commodity but also covers equipment used to process goods so they become usable, marketable, or fit for further treatment. Decorticating units therefore fall within the entry, and legislative history and later amendment supported the view that both decorticating millers and oil millers were included.

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Issues: Whether the word "miller" in item 3-C of Schedule IV of the Andhra Pradesh General Sales Tax Act, 1957 includes a decorticating miller as well as an oil miller.

Analysis: The expression "miller" was not defined in the Act and had to be understood in its ordinary and popular sense in the context of the statutory scheme and legislative history. The Court applied the common parlance approach and held that the word "mill" is not confined to a machine that produces a new commodity; it also includes machinery used for processing goods so as to make them usable, marketable, or fit for further treatment. On that basis, decorticating units, which remove the husk and produce kernel through machinery, fall within the ordinary meaning of "mill". The Court further relied on the legislative history and subsequent amendment to support the conclusion that the earlier entry covered both categories of millers.

Conclusion: The word "miller" includes both decorticating millers and oil millers, and the petitions challenging tax liability failed.

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