JUDGMENT

Bharucha, J.-Leave granted in the special leave petitions.

2. These appeals call for the interpretation of Entry 24-B of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1937

3. The controversy would be clearer if both Entries 24-A and 24-B are reproduced. They read thus :

S.      Description of Point of Rate of Effective No. Goods Levy Tax    from

24-A Vegetable oils (non-refined) including groundnut, palm oil, sunflower oil, soya bean oil, mustard oil, kusum oil, tobacco seed oil, castor oil, washed cotton seed oil other than rice bran oil and coconut oil (1204)

24-B Vegetable oil (refined) obtained from non-refined oil mentioned in tem 24A other than rice bran oil (1205)

4. The Government of Andhra Pradesh issued a circular on 16th September, 1997 in regard to Entry 24B. It said : "Since there is a specific mention of the non refined oils which are linked to refined oils in item 24-B the only interpretation that can be offered is that the concessional rate of 2% is applicable only to those oils which are obtained from non refined oils subject to tax under Entry 24-A