JUDGMENT

RANGANATHAN, J:— A common question is involved in all these matters which are, therefore, being disposed of by this common judgment. The question is whether tobacco seed oil and tobacco seed cake are entitled to exemption under the A. P. General Sales Tax Act, 1957 (hereinafter referred to as the Act). The question arises in the following circumstances.

2. Section 8 of the Act confers an exemption from sales tax in respect of certain goods. It provides that:

Subject to such restrictions and conditions as may be prescribed including conditions as to licence fees, a dealer who deals in the goods specified in the fourth schedule shall be exempt from tax under this Act in respect of such goods.

Entry 7 in the fourth Schedule was tobacco and all its products.

3. The Andhra Pradesh High Court in Amara Purushotham Mamidi Obaian and Co. v. State of A. P., (1972) 29 STC 654, was called upon to consider whether tobacco seed, tobacco seed oil and tobacco seed cake were exempt from sales tax under the above provision. The Bench held that tobacco seeds could be said to be tobacco only so long as they remain attached to the plant. They, however, ceased to be tobacco the moment they are remo