Interpretation of statutory terms should be based on their natural, ordinary, or popular sense, and should align with the common understanding of the subject matter.

Paripoornan, J.

The same person is the petitioner in both the revisions. He is a dealer in bakery products, tobacco products etc. He is a dealer under the Kerala General Sales Tax Act. The Revenue is the respondent in both the revisions. We are concerned with the assessment years 1986-87 and 1987-88. The assessee returned a taxable turnover of Rs. 6,664.35 for 1986-87 and Rs. 20,516.90 for 1987-88. The Sales Tax Officer rejected the returns and assessed the dealer on a taxable turnover of Rs. 27.010/- and Rs. 61,2907-respectively. The appeals filed by the dealer before the Appellate Assistant Commissioner were dismissed. In second appeals (T. A. Nos. 142 and 143 of 1991), the Sales tax Appellate Tribunal, Additional Bench, Palakkad allowed the appeal for the year 1986-87 to a limited extent and dismissed the appeal for the year 1987-88 in toto. Aggrieved by the common order passed by the Tribunal in T.A.Nos.142 and 143 of 1991 dated 17-5-1991, the assessee has filed the above two revisions.

2. We heard counsel for the assessee Mr. K.C. Balagangadharan as also counsel for the Revenue - Senior Government Pleader Mr. V.C. James.

3. The main plea of the assessee before the Tribunal and also before us is to the effect that the taxable turnover fixed for both the years includes general goods, taxable under S.5 of the Act and that the assessee is not liable to be assessed for the turnover of general goods, since the total turnover fixed is below rupees one lakh for both the years. The plea of the Revenue was that the assessee had no dealing in general goods and that the taxable turnover fixed for both the years represents the sales turnover of bakery items covered by the entry 'bakery products' in the first schedule to the K.G.S.T.Act. Entry 9 of the first schedule to the K.G.S.T. Act prior to 1-7-1987 is to the following effect: Similarly entry 15 of the first schedule to the K.G.S.T. Act with effect from 1-7-1987, is as follows:

"15. Bakery products excluding At the point of first sale in the bread and biscuit. State by a dealer who is liable to 5 tax under S.S.

4. The main thrust of the assessee 's plea is to the effect that goods which are not baked will not come under bakery products. It was argued that all goods made or sold by a baker cannot be called "bakery products". Bakery products can denote only those goods which are ordinarily and usually baked in an oven, such as bread, bun, rusk, cakes and biscuits. In this case, the assessee produced and sold sweets such as halva, laddu, jilabi and gulab jamun and fried food articles such as banana chips, tapioca chips, murukku, fried ground nut etc. These items are not baked in an oven and they will not come under bakery products and taxed as such.

5. Counsel for the respondent/ Revenue contended that admittedly the goods were produced or made and sold by the assessee, who is a dealer in bakery and sweet items, and so the said items sold by him will be bakery products coming within the relevant entry in the first schedule to the K.G.S.T. Act.

6. The crucial issue to be decided in this case is whether banana chips, Achappam, Mixture, Murukku, Pakkavada, fried ground nuts etc., made and/or sold by a baker can be called bakery products as specified in the first schedule to the K.G.S.T. Act. The Appellate Tribunal has taken the view that the entry in the first schedule excludes bread and so the word 'bakery products' in the first schedule necessarily means anything connected with a bakery or dealt with by a baker, as bakery goods. Banana chips, murukku, ahappam, pakkavada and mixture are popularly known as bakery goods and so they are covered by the word 'bakery products' as specified in the relevant entry in the first schedule to the K.G.S.T. Act. The Appellate Tribunal concluded that these items are ordinarily dealt with in a bakery or generally sold in a bakery and in common parlance they are bakery products, since these items are normally available in a bakery.

7. We are of the