1978 (12) TMI 159

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....e point that is raised in this tax revision case, preferred by the revenue, is very simple. It relates to the meaning of the word "miller" used in item 6 of the Third Schedule of the Andhra Pradesh General Sales Tax Act. The assessee purchased groundnut and got it decorticated. However, they (the assessee-firm) did not own any groundnut mill, nor are they lessees of any such mill. They only got....

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.... consequently, the revenue has preferred this tax revision case. The material entry, which relates to levying tax on groundnut, is item 6 of the Third Schedule to the Act. It reads: "Groundnut or peanut. When purchased by a miller other than a decorticating miller in the State at the point of purchase by such miller and in all other cases at the point of purchase by the last dealer who buys ....

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.... that there might be apparent conflict on this aspect of the matter, we might as well extract the following passage from the latter decision, which occurs at page 142: "We think that all the deeming and adding can and should be avoided by literally construing the word 'miller' to signify a person functioning as a miller, that is to say, who converts groundnuts into oil." Therefore, there is ....