Judgment

ALAGIRISWAMI, J. :- The question for decision in these cases is about the liability to sales tax under the Andhra Pradesh General Sales Tax Act of watery coconuts . The Act contains four schedules. The First Schedule contains goods in respect of which a single point sales tax only in leviable under Section 5 (2) (a). The Second Schedule contains goods in respect of which a single point purchase tax only is leviable under Section 5 (2) (b). The Third Schedule contains declared goods in respect of which a single point tax only is leviable under Section 6. The Fourth Schedule contains goods exempted from tax under Section 8. By an amendment made in 1961, there was till 1963 only one entry; coconuts , in The Third Schedule and the Fourth Schedule contained tender coconuts which are useful only for drinking purposes which were exempted from tax. An explanation to the Third Schedule read as follows :

The expression coconuts in this Schedule means fresh or dried coconuts, shelled or unshelled including copra, but excluding tender coconuts.

By amending Act XVI of 1963 this explanation was replaced by another explanation, which read :

The expression coconuts in this