These three revision applications are directed against the order dated 20-9-67 by the Deputy Commissioner, Commercial Taxes (Appeals) Ajmer in respect of the assessments for the year 1961-62 1962-63, and 1963-64 in the case of M/s Abdul Shakoor Allabeli of Bhilwara. As the same points are involved, these applications are disposed of by one order. The points made out on behalf of the applicant before me were as follows: — (1) That the list contained in column 3 against Serial No. 8 of the Schedule to the Rajasthan Sales Tax Act is only illustrative and exemption is not restricted to goods included in the list. (2) That, in any case. Charas which is the subject matter of these applications, is synonymous with Persian wheel or is a part of it and is covered by No. (9) of the list. (3) That the argument adopted in the order of the Deputy Commissioner (Appeals)that a separate Notification exempting Charas was subsequently issued by the State Government and Charas could not, therefore, be deemed to be covered by any of the items in the said list, is erroneous. (4) That since a previous Deputy Commissioner had held Charas to be an agricultural implement, it was not open to the Deputy Commissioner who passed the impugned order to hold a different. (5) That the duplicate set of books alleged to have been found at the business premises of the dealer did not pertain to that business and concealment of turnover determined on the basis of those books was, therefore, unfounded. (6) That since the appellate authority reduced the turnover as determined by the assessing authority, he should also have reduced the amounts of penalty. In regard to point (1), that the list is only illustrative, no ruling was cited by counsel for the assessee to support the interpretation. He only asserted that the list could not be treated as being an exhaustive list of agricultural implements and machinery. The departmental representative, on the other hand, argued that there is nothing in the list to show that it is only illustrative. I have considered the matter. The intention of the provision will have to be gathered from the words used, giving to the words their plain, normal, grammatical meaning. Doing so, it does not appear to be possible to hold that what was intended was to give only examples of agricultural implements and machinery. I have considered the matter. The intention of the provision will have to be gathered from the words used, giving to the words their plain, normal, grammatical meaning. Doing so, it does not appear to be possible to hold that what was intended was to give only examples of agricultural implements and machinery. If the legislature intended the list to be only examples, the language would certainly have been different. A plain reading of the language shows that the intention was to specify definitively the goods which are to be treated as agricultural implements and machinery for the particular purpose of the entry against S. No. 8 of the Schedule. I hold, therefore, that exemption in respect of agricultural implements and machinery under S. No. 8 of the Schedule to the Rajasthan Sales Tax Act is available only in respect of those covered by the list given in column 3 against that serial number and their parts. Regarding point (2), counsel for the assessee relied on the argument advanced by him before the appellate authority that Charas is synonymous with Persian wheel according to one of the several meanings given to Persian wheel in the Bhartiya Vyavaharik Kosh by Vishvanath Dinkar. The departmental representative on the other hand, relied on the meaning given in the Dictionary by Dr. Raghuveera, (which admittedly is an authoritative English-Hindi Dictionary) quoted in the appellate decision. In that dictionary. Persian wheel5 has been translated as only Rahat. The departmental representative also argued that in construing exemption provisions, the strict interpretation should be adopted. He also argued that the word should not be construed in any technical sense but in the popular sense or what may be described as the sense in which it is understood in common parlance. He cited in this connection the Supreme Court judgment in the case of Ramavatar Budha Prasad v/s Assistant Sales Tax Officer, Akola and another (1961 STC XII page 286). He said, Charas in common parlance does not refer to Persian-wheel. The sense in which Charas is understood in this State in common parlance is certainly not that of a Persian Wheel, or any other kind of water-wheel, or a part thereof. What is called Charas here is a kind of large bucket made commonly of leather but also of iron used independently and not as part of a Persian Wheel or of any other kind of water-wheel. What is called Charas here is a kind of large bucket made commonly of leather but also of iron used independently and not as part of a Persian Wheel or of any other kind of water-wheel. Counsel for the assessee had nothing to support his contention except the meanings in the dictionary by Vishvanath Dinkar. He had also nothing else to say in regard to the common parlance aspect. Considering both, the Hindi meaning given to Persian Wheel in the dictionary by Dr. Raghuveer and the sense in which Charas is commonly understood in the State, I am unable to hold that Charas can be treated as Persian Wheel. Charas as commonly understood here is also not a part of a Persian Wheel. It is, therefore, not covered by No.(9) of the list in column 3 against S. No.- 8 of the Schedule to the R. S. T. Act. In regard to point (3) it is true that the Deputy Commissioner (Appeals) did refer to Government Notification dated 21-4-1964, by which Charas was specifically exempted, to support his view that Charas was not covered by the entry under discussion. In support of his contention that the subsequent Notification could not be used to interpret the entry, learned counsel for the assessee cited the decision of the Financial Commissioner (Taxation) Pepsu in the case of Burma Nand Iron Works (1956 STC VII 282). I agree that the subsequent Notification does not debar independent interpretation of the entry in the schedule. This is however, not material, in view of the conclusions arrived at by me in regard to points (1) and (2). In regard to point (4), that the Deputy Commissioner could not hold a view different from that taken by his predecessor in regard to this matter, no decisions of the previous Deputy Commissioner were produced or cited before me. It is not, therefore, possible to interfere with the Deputy Commissioners order on this ground. In regard to point (5) that the books of account seized from the business premises of the assessee did not pertain to his business, the record shows that the books were seized on| 27-6-1964. It is not, therefore, possible to interfere with the Deputy Commissioners order on this ground. In regard to point (5) that the books of account seized from the business premises of the assessee did not pertain to his business, the record shows that the books were seized on| 27-6-1964. The seizure memo contains the following sentence: ^^nkSjku inspection O;kikjh dh nqdku ij dqN Note Book ykbZu nkj dkxt dh feyh ftu ij nqdku dh [kjhn fcØh dk fglkc fy[kk gqvk gS o jksdM+ gS budk feyku buds Regualr Books ls fd;k x;k rks tek [kpZ gksuk ugha ik;k x;k ftlls tkfgj gksrk gS fd O;kikjh viuh fcØh fNik dj Sale Tax dk evasions djrk gSA If any of the books that were seized, and with reference to which tax was held to have been evaded, did not pertain to the assessees business, objection should have been raised at that stage itself. There is an application dated 16-10-1964 (i.e. about 4 months later) signed by Abdul Karim addressed to the assessing authority, in which it is stated that "the books of accounts which were seized had been written by Abdul Shakoor and in his own individual capacity." implying per haps that they pertained to Abdul Shakoors separate individual business and not to the business of the assessee firm. This is, however, followed by another paragraph in the same application as follows. If your goodself deem that these sales are also of the A.O.P. Abdul Shakoor Allah Beli the sales figures are admitted that these are correct figures from the copies seized." The point that the seized books pertained to another separate and independent business not connected with the assessee firm was thus not firmly pressed even in this application. The assessing authority had the books before him and had the opportunity to judge their nature. Having considered the application dated 16-10 64 and the books in question, the assessing authority held that concealment of turnover by the assessee was involved. The appellate order also contains the following sentence: "There is no doubt that from the business premises of the dealer duplicate set of accounts books were seized which proved suppression of sales." The appellate authority was obviously satisfied on perusal of assessment record of the case that the seized books pertained to assessees business. The appellate order also contains the following sentence: "There is no doubt that from the business premises of the dealer duplicate set of accounts books were seized which proved suppression of sales." The appellate authority was obviously satisfied on perusal of assessment record of the case that the seized books pertained to assessees business. Nothing has been brought out before me which would justify my holding in regard to point (5) a view different from that adopted in the assessment and appellate orders. In regard to point (6 that the appellate authority should have reduced the amounts of penalties, there is clear observation in the appellate order that considering the extent of suppression of sales the penalties were not high. The appellate authority thus duly considered the actual suppression of sales discovered, and held the penalties to be justified with reference to it. The conclusion is in no way illegal, improper or erroneous. I see no reason to interfere with it. The revision applications are, therefore rejected.