Plain meaning in tax law excludes water-bearing coconuts from "dried coconuts"; writ relief remained available despite alternative remedies.

Fully grown coconuts containing water were held not to fall within the expression "dried coconuts" in the Third Schedule, because the statutory definition was exhaustive and a taxing entry must be applied according to its plain words without enlargement by implication. The omission of "fresh" from the amended explanation reinforced the narrower scope of the term, so purchases of such coconuts could not be taxed under the relevant schedule. The availability of objections or an appeal did not automatically bar writ relief where the assessment was challenged as without jurisdiction and coercive recovery was threatened, so the writ petitions were maintainable under Article 226.

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Issues: (i) Whether fully grown coconuts containing water, but not tender coconuts, fall within the expression "dried coconuts" in the Third Schedule to the Andhra Pradesh General Sales Tax Act; (ii) Whether the existence of an alternative statutory remedy barred relief under Article 226 of the Constitution of India.

Issue (i): Whether fully grown coconuts containing water, but not tender coconuts, fall within the expression "dried coconuts" in the Third Schedule to the Andhra Pradesh General Sales Tax Act.

Analysis: The explanation to the Third Schedule defined "coconuts" as dried coconuts, shelled or unshelled, including copra, but excluding tender coconuts. The earlier explanation had covered both fresh and dried coconuts, but the later amendment omitted the word "fresh", which indicated a narrower class. The expression "dried coconuts" could not reasonably be stretched to include fully grown coconuts still containing water. In a taxing statute, only the clear words used can be applied, and nothing can be read in by intendment. The definition using the word "means" was treated as exhaustive, not illustrative.

Conclusion: Fully grown coconuts containing water were not "dried coconuts" within the Third Schedule, and their purchases could not be taxed under section 6 read with that Schedule.

Issue (ii): Whether the existence of an alternative statutory remedy barred relief under Article 226 of the Constitution of India.

Analysis: The assessment orders were challenged as being without jurisdiction and contrary to law, and the petitioners faced immediate coercive recovery and possible penalty. The existence of objections before the assessing authority and a further appeal was treated as only a rule of discretion, not an inflexible bar. Where immediate harm is threatened and the impugned action is alleged to be without jurisdiction, the High Court may entertain a writ petition despite alternative remedies.

Conclusion: The writ petitions were maintainable under Article 226 notwithstanding the availability of other remedies.

Final Conclusion: The impugned provisional assessments could not stand, and the petitions succeeded with costs.

Ratio Decidendi: In a taxing statute, a defined expression must be given its plain and exhaustive meaning, and where an assessment is attacked as without jurisdiction and immediate coercive recovery is threatened, the existence of an alternative remedy does not necessarily bar writ relief.

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