1. The short question arising for determination in this Tax Revision Case is whether the cloth manufactured by the aid of powerlooms is exempted from sales tax in view of S.SA 1 (i) of the General Sales Tax Act, 1125. The relevant part of the section is in these terms: -

"5A. Exemption of tax on the sales of mill-made textiles (other than pure silk), tobacco and sugar. (1) The sale by any dealer of -

(i) mill-made textile, other than pure silk,

(ii)

2. It is agreed that the commodity with which we are concerned in this case is not silk. It is also admitted that the cloth with which we are concerned is manufactured in powerlooms and further that those powerlooms are housed in a factory.

3. The question therefore is whether such cloth can be said to fall within the term "mill-made textile" used in S.SA (1) (i). Under the Sales Tax Act, as we read it, textiles have been divided into two; those that are made in handlooms and those that are made with the aid of machines. "Mill" can have two meanings, machine, or a mill understood in the popular sense meaning the building or the factory in which machines are housed. We are inclined to take the view that even if cloth is made in po