TMI Blog1978 (12) TMI 159X X X X Extracts X X X X X X X X Extracts X X X X ..... e meaning of the word "miller" used in item 6 of the Third Schedule of the Andhra Pradesh General Sales Tax Act. The assessee purchased groundnut and got it decorticated. However, they (the assessee-firm) did not own any groundnut mill, nor are they lessees of any such mill. They only got the groundnuts decorticated in other mills. Part of the groundnut they got crushed into oil in some mill, wh ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ng tax on groundnut, is item 6 of the Third Schedule to the Act. It reads: "Groundnut or peanut. When purchased by a miller other than a decorticating miller in the State at the point of purchase by such miller and in all other cases at the point of purchase by the last dealer who buys in the State." It was admitted before the Tribunal and also before us and, in fact, even by the assessing aut ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e from the latter decision, which occurs at page 142: "We think that all the deeming and adding can and should be avoided by literally construing the word 'miller' to signify a person functioning as a miller, that is to say, who converts groundnuts into oil." Therefore, there is no doubt that a miller, as it is used in item 6 of the Third Schedule, is a person, who owns or works a mill either ..... X X X X Extracts X X X X X X X X Extracts X X X X
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