( 1 ) THE reference to the Full Bench is made by Mr. Justice M. N. Rao and mr. Justice T. N. C. Rangarajan as they were at that time expressing a doubt as to the correctness of the judgment in State of Andhra Pradesh vs. M/s. Jayanti oil Mills Private Limited. The facts in brief are as follows: the assessee is a dealer in groundnut oil. It has a Solvent Extract Plant at Guntakal where it extracts groundnut oil from groundnut oil cake which has already suffered tax. On the footing that such oil falls within the Entry 24 (b) in the First Schedule to the Andhra Pradesh General Sales Tax Act (for short the Act ) the assessee has paid tax only at the rate of 2 paise in the rupee and assessments have been completed on that basis for the assessment year 1993-94. However, the impugned notices have been issued for bringing the said sales of groundnut oil within the scope of Entry 24 (a) on the ground that the oil has been extracted not from the groundnut but only from groundnut oil cake and it will not, therefore, fall within the Entry 24 (b ). For this proposition the basis is the decision of this Court in M/s. Jayanti Oil Mills case.

( 2 ) IT was argued by the learned