Processed milk remains milk for sales tax exemption when its essential identity is unchanged.

Condensed milk was treated as falling within a sales tax exemption for "milk" because its processing by dehydration and addition of sugar or preservative did not alter its essential identity. Applying the common or popular understanding of milk, the product remained milk despite transformation, and partial processing alone was insufficient to remove it from the exemption. The revision seeking to deny the exemption therefore failed, and condensed milk continued to qualify for exempt treatment as milk.

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Issues: Whether condensed milk falls within the exemption for "milk" under the sales tax notification.

Analysis: The exemption notification covered sales of milk. Condensed milk is obtained by dehydrating milk and adding sugar or preservative, but the process does not change its essential character. Applying the common understanding of milk, the product remains milk notwithstanding processing, and the fact that some transformation occurs does not by itself take it outside the exemption.

Conclusion: Condensed milk is exempt as milk; the assessee's claim fails insofar as the revision sought to deny that exemption.

Ratio Decidendi: A processed form of milk does not cease to be milk for the purpose of a sales tax exemption if its essential identity remains that of milk in popular understanding.

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