( 1 ) THESE two writ petition raise a common point. The petitioners are miller-dealers having obtained licence under the provisions of the Rice Milling Industry Regulation Act, 1952 and are financed by the Khadi and Village Industries Board. But that alone is not sufficient for claiming exemption from the sales tax as declared under G. O. Ms. No. 2566, Revenue (S) Department, dated 11/06/1980. The said Government Order grants exemption only to the processing of cereals and pulses industry and the question is whether rice comes within that item and definition.

( 2 ) A look at Third Schedule to the Andhra Pradesh General Sales Tax Act, 1957 at items 20 to 22 clears the mist as cereals are separately and specifically defined at item 20, while paddy at item 21 and rice at item 22. When the word "cereals" is used without specifying the paddy and rice, there may be a question for consideration as the paddy and rice come within the general definition of "cereals"; but when specifically it was mentioned in the Schedule separating the paddy and rice from cereals, it only means that the exemption does not cover the paddy and rice.

( 3 ) IN the circumstances, these writ petitions, which are devoid on merits, are dismissed; but without costs.