RAJAGOPALA AYYANGAR, J.

The decision in this batch of tax revision cases involves the construction of rule 18(2) of the Turnover and Assessment Rules framed under the Madras General Tax Act. The material portion of rule 18 of the Turnover and Assessment Rules whose construction we are called on to decide runs thus :

"18(1). Any dealer who manufactures groundnut oil and cake from groundnut and/or kernel purchased by him may, on application to the assessing authority having jurisdiction over the area in which he carries on his business, be registered as a manufacturer of groundnut oil and cake.

(2) Every such manufacturer shall be entitled to a deduction under clause (k) of sub-rule (1) of rule 5 equal to the value of the groundnut and/or kernel purchased and converted by him into oil and cake provided that the amount for which the oil is sold is included in his turnover.

Explanation. - For the purpose of this sub-rule -

(a) 143 lb. of groundnut shall be taken to be equivalent to 100 lb. of kernel;

(b) 143 lb. of groundnut or 100 lb. of kernel shall, when converted into oil, be taken to yield 40 lb. of oil; and

(c) one candy of oil shall be taken to be equivalent to 500 lb. of o