1. The first question for consideration in these petitions is whether 'green ginger' is liable to taxation under the General Sales Tax Act, 1125. Both the petitions are by the same person.

2. The period covered by the assessment order challenged in O.P. 767 of 1959 -Ext. A-is the period from 1-10-1957 to 31-3-1958, and the period covered by the assessment order challenged in O.P. 542 of 1960 - Ext. A-is the period from 1-4-1958 to 31-3-1959.

3. Counsel for the petitioner relies on two notifications of the Government in support of the non-liability to taxation claimed in respect of 'green ginger", one dated 15-6-1950 and issued by the Travancore-Cochin Government, and another dated 25-3-1958, and issued by the Government of Kerala. Both the notifications were issued under S.6 of the Act. The item exempted was described as follows:

"Vegetables including tapioca except its manufactured product."

This exemption applied for the period 1-10-1957 to 1-10-1958. Though the earlier notification dated 15-6-1950 insisted on a licence being taken for claiming the benefit of exemption, the notification dated 25-3-1958 did not impose any such condition. The implications of this will be de