JUDGMENT : ( 1. ) THE order in this case will also govern the disposal of Miscellaneous Civil Case No. 336 of 1984 as a common question of law is involved in both these references. ( 2. ) BY these references under Section 44 (1) of the Madhya Pradesh General Sales Tax Act, 1958 (hereinafter referred to as "the Act"), the Board of Revenue has referred the following question of law to this Court for its opinion : Whether, on the facts and in the circumstances of this case, the Board of Revenue was justified in holding that the husk of soyabean was liable to be taxed as the same was not covered by Notification No. 1073-537-V-ST dated 7th April, 1967, as extended from time to time and consequently it was not exempt from payment of turnover tax ? ( 3. ) THE material facts giving rise to these references, briefly, are as follows : While framing the assessment of the assessee under the Act, the contention of the assessee that the husk of soyabean was exempt from tax under the notification dated 7th April, 1967, was not upheld by the Sales Tax Officer and the appeal preferred by the assessee in that behalf was also dismissed. On further appeal before the Board, the learned President of the Board held that soyabean had to be treated as an oil-seed for the purposes of the Act and was not exempt from tax as urged on behalf of the assessee. In this view of the matter, the second appeal preferred by the assessee was dismissed. Aggrieved by the order passed by the Board, the assessee sought reference and it is at the instance of the assessee that the aforesaid question of law has been referred to this Court for its opinion. ( 4. ) SHRI Chaphekar, the learned counsel for the assessee, contended that Notification No. 1073-537-V-ST dated 7th April, 1967, issued by the State Government in exercise of the powers conferred by Section 12 of the Act specifically exempted husk of all grains, cereals, pulses and rice and that as soyabean was a kind of cereal, husk of soyabean was exempt from tax. The learned counsel for the assessee further contended that the Board was not justified in referring to the provisions of Section 14 of the Central Sales Tax Act for construing the meaning of the terms occurring in the notification issued under Section 12 of the Act. ( 5. ) THE short question for consideration in this case is whether husk of soyabean is or is not covered by notification dated 7th April, 1967. It is not disputed that the said notification exempts husk of all grains, cereals, pulses and rice from the payment of tax under the Act and that the said notification was in force at the material time. The expression "cereal" has not been defined in the Act. It connotes any grain used for food. Soyabean is undoubtedly used for food. Any particular species of grain cannot be excluded from the category of grain merely because it is capable of being used as an oil-seed as well. The Board seems to be of the opinion that under Section 14 of the Central Sales Tax Act, as soyabean has been included in the category of oil-seeds, it would cease to be cereal. There is no justification for coming to that conclusion. In our opinion, the Board was not justified in holding that husk of soyabean was not exempt from tax as it was not covered by the notification dated 7th April, 1967. ( 6. ) FOR all these reasons, our answer to the question referred to this Court is in the negative and in favour of the assessee. In the circumstances of the case, parties shall bear their own costs of these references.