( 1 ) THE short question that arises for consideration in this tax revision case is whether the groundnut oil extracted from groundnut cake is eligible to tax at the reduced rate under entry 24 (b) of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957. It would be useful to read here entry 24 of the First Schedule to the Act. @@ ---------------------------------------------------------------------- "sl. No. Description of goods Point of levy Rate of tax ---------------------------------------------------------------------- 24. Groundnut oil or refined oil - (a) Groundnut oil or At the point of 6 paise in refined oil not first sale in the the rupee. covered by sub- State. item (b) below; (b) Groundnut oil - do - 2 paise in or refined oil the rupee. " obtained from groundnut that has met tax under the Act.----------------------------------------------------------------------@@ A plain reading of the entry would show that when the raw material for extracting the groundnut oil is tax-suffered "groundnut" the reduced rate of 2 per cent prescribed under (b) would apply; for all other types of groundnut oil the rate of 6 per cent prescribed under (a) would apply.

( 2 ) I

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