Ordinary commercial meaning of rice controlled classification, so ravva was treated as exempt second sale under the sales tax entry.

Ravva was treated as falling within the ordinary commercial meaning of "rice" under entry 66 of the A.P. General Sales Tax Act. The analysis applied the principle that a schedule entry is construed by common understanding of the commodity, and held that the process of making ravva was no more elaborate than the processing already accepted for parched rice and puffed rice. The later amendment creating a separate ravva entry was not relevant to the period in dispute. On that basis, sale of ravva was treated as a second sale and not liable to tax, and the assessee's claim to exemption succeeded.

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Issues: Whether ravva falls within the expression "rice" under entry 66 of the First Schedule to the A.P. General Sales Tax Act, and whether its sale is therefore taxable or exempt as a second sale.

Analysis: The decisive consideration was the ordinary understanding of the commodity under the relevant tariff entry. Rice had already been held to include parched rice and puffed rice, and the process by which rice is converted into ravva was treated as no more elaborate than those processes. The later amendment introducing a separate entry for ravva was not material to the period in dispute. The earlier precedent governing rice in the statutory entry was therefore applied to the commodity in question.

Conclusion: Ravva was held to be rice within entry 66, and its sale was held to constitute a second sale not liable to tax.

Final Conclusion: The revisions were rejected because the commodity was treated as falling within the existing rice entry, with the result that the assessee's claim to exemption succeeded.

Ratio Decidendi: A commodity falls within a schedule entry according to its ordinary commercial understanding, and a less elaborate processed form of rice remains rice for purposes of the sales tax entry.

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