JUDGMENT

Dalveer Bhandari, J.—

1.These appeals are directed against the judgment dated 8th May, 2001 passed by the High Court of judicature, Andhra Pradesh at Hyderabad in Tax Revision Case No.89/94, Tax Revision Case No.90/94 and Writ Petition No. 32154 of 1998.

2.Brief facts which are necessary to dispose of these appeals are recapitulated as under :

3.The appellant is engaged in the business of purchasing various spices like Cumin Seed (Jeera), Fenugreek Seeds (Methi), Cinnamon (Dalchini), Caraway Seeds (Shahijeera) etc. from the registered dealers in the State of Andhra Pradesh and the said items are subjected to sales tax at the point of first sale under Entry No.182 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 (hereinafter referred to as the “APGST Act, 1957”). All the said items are called “spices. The appellant by mixing and grinding all these spices together produces” masala powder which is used for enhancing the taste of food.

4.The appellant filed income-tax returns for the assessment years 1990-91, 1991-92, 1992-93 claiming exemption on the ground that the ingredients used for the preparation of masala powder have already been taxed under E