Meaning of "miller" under sales tax law excludes occasional users of milling facilities, the court held.

The term "miller" in item 6 of the Third Schedule to the Andhra Pradesh General Sales Tax Act was construed in its ordinary sense because it was not defined in the Act. It refers to a person who owns or works a mill, either as proprietor or tenant, and the phrase "other than a decorticating miller" reinforced that the entry targets a person functioning as a miller rather than one who merely uses milling facilities occasionally. On that interpretation, a person who only gets groundnuts crushed in another mill for individual transactions is not a miller. The assessee was therefore not liable to assessment on that basis.

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Issues: Whether a person who merely engages outside mills on occasion for crushing groundnut kernel, without owning or leasing a mill, falls within the expression "miller" in item 6 of the Third Schedule to the Andhra Pradesh General Sales Tax Act.

Analysis: The expression "miller" was not defined in the Act and was therefore construed in its ordinary sense. The term was taken to mean a person who owns or works a mill, either as proprietor or as tenant. On that construction, a person who only gets groundnuts crushed in another mill for individual transactions does not become a miller. The expression was also read with the words "other than a decorticating miller", which supported the conclusion that the entry applied to a person functioning as a miller and not merely to one who occasionally uses milling facilities.

Conclusion: The assessee was not a "miller" within item 6 and was not liable to be assessed on that basis.

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