GOPALAN NAMBIYAR, C.J.

These appeals, tax revisions and the writ petitions raise an interesting question regarding the meaning of the expressions "frozen meat" and "fresh fish" occurring in an exemption notification issued under section 10 of the Kerala General Sales Tax Act, 1963. We quote the said notification and the two relevant entries in the First Schedule thereto :

"S.R.O. No. 342/63. - In exercise of the powers conferred by section 10 of the Kerala General Sales Tax Act, 1963 (Act 15 of 1963), the Government of Kerala having considered it necessary in the public interest so to do hereby make an exemption in respect of the tax payable under the said Act on the sale or purchase of the goods specified in Schedule I hereto appended and by persons specified in Schedule II hereto appended in regard to their turnover on the sales of goods specified therein subject to the conditions specified therein."

SCHEDULE I

"23. Fresh fish.

25. Meat except meat which is cured or frozen."

With respect to these entries extracted above, the question which arises for consideration in what is the meaning to be attributed to the terms "fresh fish" and "frozen meat". We may notice the facts