Concessional sales tax on refined vegetable oil applies to oil derived from specified non-refined inputs without prior tax on the input.

Refined vegetable oil obtained from the non-refined oil described in Entry 24-A of the Andhra Pradesh General Sales Tax Act was held to fall within Entry 24-B without any requirement that the input oil had already suffered tax under Entry 24-A. The word "mentioned" in Entry 24-B was construed as "described" or "set forth", and the Schedule's wording showed that where a taxable-input condition was intended, it was expressed expressly. On that construction, the concessional rate applied to all refined vegetable oil derived from the specified non-refined oil, and the assessee's interpretation was accepted.

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Issues: Whether refined vegetable oil obtained from non-refined oil described in Entry 24-A of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 is taxable at the concessional rate under Entry 24-B only if the non-refined oil had already suffered tax under Entry 24-A.

Analysis: The wording of Entry 24-B was held to cover all refined vegetable oil obtained from the kinds of non-refined oil described in Entry 24-A, namely non-refined oil other than rice bran oil. The term "mentioned" was construed in its ordinary sense as "described" or "set forth" and not as a requirement that the input oil must first have suffered tax. The structure of the Schedule showed that when the legislature intended to restrict a concession to goods made from taxed inputs, it said so expressly; the omission of such words in the amended entries confirmed that no such limitation could be read into Entry 24-B.

Conclusion: Entry 24-B applied to all refined vegetable oil obtained from the oil described in Entry 24-A, and not only to oil derived from inputs already taxed under Entry 24-A. The assessee's interpretation was accepted.

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