ORDER :

1. The present Sales Tax Revisions / References (for short “STRs”), filed under Section 84 of the Rajasthan Value Added Tax Act, 2003 (for short “RVAT Act”), were admitted on following questions of law:

“(i) Whether the learned Tax Board is justified in holding that Kurkure and Cheetos are not classifiable as Namkeen under Entry 131 of Schedule IV, holding that the products will fall under Schedule V (Residual Rate) of the VAT Act, just because similar contention was turned down while interpreting different entries under the erstwhile Rajasthan Sales Tax Act, 1994?

(ii) Whether the learned Tax Board is right in adopting a restricted meaning for the term “namkeen” in interpreting the scope of Entry 131 of the Schedule IV?”

2. As common issue of classification of ‘Kurkure’ and ‘Cheetos’ is involved in all these STRs, with the consent of the parties, they were heard together and are now being decided by way of this common order. STR No. 119/2020 is taken as lead file to peruse the facts.

3. Learned counsel for the petitioner-assessee submits that the petitioner-assessee is a private limited company incorporated under the provisions of the Indian Companies Act 1956 having registere