JUDGMENT S. R. RAJASEKHARA MURTHY, J. - The petitioners in the first batch of cases are all dealers in household consumer durable items, such as sewing machines, electric fans, etc. The petitioners in the second batch of cases are all dealers in sewing machines and spare parts. 2. The petitioners have stated in the writ petitions that the sewing machines sold by them are meant for use as domestic appliances by house-wives and used by small time tailors. They have also further asserted that these sewing machines sold by them have no industrial application. All the petitioners are aggrieved by the show cause notices proposing to levy entry tax on sewing machines and treating them as "industrial machinery" under entry 7 of the Schedule to the Karnataka Tax on Entry of Goods into Local Areas for Consumption, Use or Sale therein Act, 1979 ("the Act" for short). 3. The Act passed by the State Legislature as Karnataka Act No. 27 of 1979 was brought into force with effect from 1st October, 1980. The object of the Act is levy the tax on entry of goods into the local areas for consumption, use or sale therein. Section 3 is the charging section which empowers the levy and collection of tax on entry of the scheduled goods at the rates specified therein. Originally, the Schedule consisted of only three items :- "SCHEDULE [See section 2(7)] 1. All varieties of textiles, namely, cotton, woollen, silk or artificial silk including rayon or nylon whether manufactured in mills, power-looms or handlooms and hosiery cloth in lengths. 2. Tobacco and all its products. 3. Sugar other than sugar candy, confectionery and the like." By Act 38 of 1984, the Act was amended to include several other items and entry 7 reads thus : "7. Industrial machinery and parts and accessories thereof." Sewing machines were not subjected to tax under Entry Tax Act, under entry 7 which was inserted with effect from 1st April, 1982. Such an attempt was made by the Department pursuant to a clarification issued by the Commissioner on 21st December, 1987, directing all the assessing authorities to levy tax on sewing machines under entry 7 (old entry 4). The said clarification reads thus : "Sir, Date : 21-12-1987 Sub : Clarification on entry tax - reg. Ref : Your letter dated 30-11-1987. The said clarification reads thus : "Sir, Date : 21-12-1987 Sub : Clarification on entry tax - reg. Ref : Your letter dated 30-11-1987. 'Sewing machines' are taxable under entry 4 of the schedule to the KTEC Act, at the rate of 2 per cent irrespective of its use. Yours faithfully, Sd/- Joint Commissioner of Commercial Taxes (L)." As already stated, show cause notices were issued proposing to levy entry tax on sewing machines and assessments were also completed following the clarification issued by the Commissioner. These assessments and show cause notices are challenged in these writ petitions. Several contentions are urged by Sri Indrakumar and Sri K. R. Prasad, learned Counsel for the petitioners challenging the levy : (i) that the sewing machines cannot be classified as "industrial machinery" for purposes of levy of entry tax; (ii) sewing machines imported by the petitioners into the local area are meant for use as domestic appliances and are sold as such and they do not satisfy the description of industrial machinery; (iii) by their very characteristics, purpose, design and use, sewing machines cannot be classified as industrial machinery; (iv) the Commissioner has no power under the Act to issue clarification and to direct levy of tax on sewing machines treating them as industrial machinery irrespective of its use; (v) Explanation III inserted by Act 18 of 1989 explaining industrial machinery for purpose of entry 7 should prevail; and (vi) the clarification issued by the Commissioner, should, therefore, be declared as contrary to the Act and as not binding. The learned Government Pleader has sought to justify the levy on more than one ground. Interpreting explanation III as applying to sewing machines, it was argued that they are rightly taxed under entry 7. Secondly, the clarification issued by the Commissioner is justified as one issued in exercise of his power under section 12(3) of the Entry Tax Act. Sri K. R. Prasad argued that though the term, "industry" includes any trade or business in its wider sense, it indicates an organised activity involving the process of manufacture and production. Sewing machines which are essentially used by housewives as a domestic appliance and by tailors for stitching cannot be classified as an industrial machinery. Sri K. R. Prasad argued that though the term, "industry" includes any trade or business in its wider sense, it indicates an organised activity involving the process of manufacture and production. Sewing machines which are essentially used by housewives as a domestic appliance and by tailors for stitching cannot be classified as an industrial machinery. The expression, "industrial machinery" which is used or which is capable of being used in an industry and sewing machines dealt with by the petitioners do not answer the descriptions by their use, design and purpose. The learned counsel has also placed reliance on explanation III as inserted by Act 18 of 1989 which is declaratory in nature and makes it explicit what is meant by industrial machinery for purposes of entry 7. The said explanation is reproduced below for ready reference :- "Explanation III. - 'Industrial machinery' for the purpose of entry 7 of the Schedule shall mean such machinery which are generally used by an industrial unit whether or not such unit is a factory as defined under the Factories Act, 1948, for manufacturing or processing of goods and includes earth moving machinery and such other machinery used for mining, building, construction (including laying of roads), fabrication, erection, installation, fitting out, improvement, modification, repair or commissioning of any movable or immovable property." On the basis of this explanation, Sri Prasad has contended that the explanation virtually supports the case of the petitioners. In support of this argument, Sri Prasad has relied upon certain passages from Maxwell on Interpretation of Statutes - 12th edition, at page 223, dealing with explanations. The explanation, according to the learned author, is an amendment to the Act and can be looked into and relied upon as to explain the meaning of an entry. It was also argued that this explanation should be read as having existed always in the Act for the purpose of entry 7. Elaborating his contention, the learned counsel argued, that what was implicit in the entry as to the nature of machinery that should attract tax, was made explicit by legislature by inserting the explanation to entry 7. Therefore, what little doubt entertained by the department was eliminated and explained by the insertion of the explanation. Elaborating his contention, the learned counsel argued, that what was implicit in the entry as to the nature of machinery that should attract tax, was made explicit by legislature by inserting the explanation to entry 7. Therefore, what little doubt entertained by the department was eliminated and explained by the insertion of the explanation. The learned Counsel has relied upon the following decisions in support of his other argument that the ordinary and general construction and use of sewing machines should not be ignored while interpreting the entry. In support of this argument he relied upon the decision of this Court in J. Vamana Prabhu v. State of Mysore [1967] 20 STC 38. This Court was dealing with the interpretation of entry 29 of the Fifth Schedule to the Mysore Sales Tax Act, under which "firewood" or "charcoal" when sold for domestic use, was exempt from the levy. This Court explained, that for the purpose of interpretation of the entry in the Sales Tax Act the ordinary habits of civilised life and common use of an article should be borne in mind. It was, therefore, argued that the assertion made by the petitioners in the writ petitions that the sewing machines which are sold by the petitioners are essentially meant for use as a domestic appliance, should be accepted in the absence of any statement made to the contrary by the department. Dealing with "industrial machinery" as understood in common parlance and interpreted by courts, the learned counsel referred to a decision of the Supreme Court in State of Punjab v. Hindsons (P) Ltd. [1985] 58 STC 20 (SC); AIR 1984 SC 1803 . The point that arose for interpretation in the said case was : Whether the belts and pulleys sold as spare parts of agricultural implements are entitled for exemption from sales tax. The Supreme Court held, that the belt pulley when used in a tractor may increase the utility of the tractor for agricultural operations, but that by itself does not lead to the inevitable conclusion that belt pulley attachment is an agricultural implement. The learned counsel relied upon another decision of the Supreme Court in Mukesh Kumar Aggarwal & Co. The Supreme Court held, that the belt pulley when used in a tractor may increase the utility of the tractor for agricultural operations, but that by itself does not lead to the inevitable conclusion that belt pulley attachment is an agricultural implement. The learned counsel relied upon another decision of the Supreme Court in Mukesh Kumar Aggarwal & Co. v. State of Madhya Pradesh [1988] 68 STC 324, in which it was observed by their Lordships that, "in a taxing statute, words which are not technical expressions or words of art, but are words of every day use, must be understood and given a meaning, not in their technical or scientific sense, but in a sense as understood in common parlance. The particular terms used by the legislature in the denomination of articles are to be understood according to the common commercial understanding of those terms used and not in their scientific and technical sense." A decision of this Court in Additional Commissioner of Income-tax, Mysore v. A. L. N. Rao Charitable Trust [1976] 103 ITR 44, was also cited in support of the proposition that subsequent amendment can be utilised by court as an aid in arriving at the correct meaning of prior enactments. Commenting on the explanation itself, the learned Counsel has argued that the ingredients set out in the explanation to answer the description of "industrial machinery" must be satisfied before the department proposes to levy entry tax on sewing machines. It is argued that in the absence of any counter-statement on the factual user to bring the sewing machines within the ambit of industrial machinery, the proposed levy in these cases must fail. Elaborating the said contention, the learned counsel argued that machinery referred in the explanation must be one which is generally used by an industrial unit and further such use must be for manufacturing or processing of goods. It is, therefore, argued that the clarification issued by the Commissioner that irrespective of the use of the sewing machines, it should be treated as industrial machinery, is one issued without any application of mind and is a clear misreading of the entry. In order to be called industrial machinery, it must be used by an industrial unit for manufacturing or processing of goods and by their build, design and character, should be identified as an industrial machinery. In order to be called industrial machinery, it must be used by an industrial unit for manufacturing or processing of goods and by their build, design and character, should be identified as an industrial machinery. That sewing machines do not answer the description and cannot therefore be grouped among the type of machinery referred to in the explanation, which is in the nature of an inclusive definition of "industrial machinery", is the further argument of Sri Prasad. The learned counsel has also referred to the other entries in the Schedule, such as entry 12 : air-conditioners, refrigerators, etc., entry 13 : electrical goods of the descriptions referred to therein and the like. It is demonstrated by making a reference to these entries that the legislature has, in its wisdom, enumerated specific articles which are exigible to tax and the description of which is given in the Schedule. Sri Indrakumar, who appears for the petitioners in the second batch of writ petitions and other connected cases has, supplementing the argument of Sri K. R. Prasad, submitted that sewing machine is an ordinary machine meant for stitching and used as a household article and as an ordinary appliance by tailors. It was argued that explanation III is inserted in the Act for purpose of entry 7 and this gives a clue to the understanding of the entry. The further argument of the learned counsel is that the use of sewing machine for stitching and tailoring cannot be treated as a machinery used in an industrial unit and does not satisfy the description of the industrial machinery as clarified by the explanation. The learned counsel has relied upon the following decisions in support of his proposition that the normal and ordinary meaning attached to a particular article or goods should be adopted and has cited the following decision in support of this contention : Nat Steel Equipment Pvt. Ltd. v. Collector of Central Excise [1988] 69 STC 58 (SC). That was a case which arose under the Central Excises and Salt Act. The Supreme Court was dealing with "domestic electrical appliances". Their Lordships agreed with the observations of Shri Bhagwathi, Chief Justice of Gujarat High Court (as he then was), made in Viswa & Co. That was a case which arose under the Central Excises and Salt Act. The Supreme Court was dealing with "domestic electrical appliances". Their Lordships agreed with the observations of Shri Bhagwathi, Chief Justice of Gujarat High Court (as he then was), made in Viswa & Co. [1966] 17 STC 581, that the expression, "domestic electrical appliances" must be understood as necessarily of a kind which is generally used for household purposes, was accepted by the High Court. Dealing with explanation III and its application, the learned counsel has cited some decisions. He has relied upon the decision of the Supreme Court in Nagar Mahapalika, Bareilly v. State of U.P. [1988] 70 STC 97. That was a case arising under the U.P. Nagar Mahapalika Adhiniyam. Dealing with the principle of interpretation of entries in the Schedule, the Supreme Court held (Shri Sabyasachi Mukherji, J. as he then was), that the court should normally give the meaning intended by the framers of the Schedule by looking at the various articles mentioned in a particular group and all the items in a group should be considered in a generic sense. His Lordship also observed that the courts should give the natural meaning of an article as understood by common people and the type of the goods is always the relevant factor which must be borne in mind. The next decision relied upon by the learned counsel is the one reported in [1967] 19 STC 469 (SC) (Commissioner of Sales Tax, Madhya Pradesh v. Jaswant Singh Charan Singh). Dealing with the principle of interpretation of an entry in the schedule of the Madhya Pradesh General Sales Tax Act with reference to "coal", the Supreme Court (Shri J. M. Shelat, J.) observed, that in the absence of a technical term or a term of science or art, the ordinary meaning ascribed to an ordinary term in common parlance should be presumed. His Lordship also observed that the popular meaning or the meaning attached to a particular article by those dealing in them, that is to say, the commercial sense should always be resorted to. His Lordship also observed that the popular meaning or the meaning attached to a particular article by those dealing in them, that is to say, the commercial sense should always be resorted to. A passage from Macbeth v. Chislett [1910] AC 220, in which Lord Loreburn stated thus : "it would be a new terror in the construction of Act of Parliament if we were required to limit a word to an unnatural sense because in some Act which is not incorporated or referred to such an interpretation is given to it for the purposes of that Act alone." As regards the legislative intendment, the learned counsel relied upon a decision of this Court in the case of S. Soundarapandian v. Commissioner of Commercial Taxes, Bangalore [1980] 46 STC 211. That was a case arising under the Karnataka Sales Tax Act. While interpreting "paints", "colours", "dyes" and "varnish" in entry 97, this Court held, that the words used in the entries in sales tax laws should be understood by the meaning attached to those words at common parlance, i.e., by persons dealing in those goods and persons using those articles; and the technical meaning attached to those words and given in dictionaries could not be a safe guide for arriving at a correct conclusion. Sri Indrakumar also opposed the argument of the learned Government Pleader that the definition of an "industry" occurring in Industrial Disputes Act may he imported into the Entry Tax Act. The question that, therefore, arises for decision on these arguments is : whether sewing machines are exigible to levy of entry tax as industrial machinery under entry 7 ? Let me first analyse the entries in the Entry Tax Act, which gives an indication as to the object of the legislature to tax the entry of certain goods into a local area. To start with, the Schedule contained only three goods, viz., textiles, sugar and tobacco and its products. Later, the Schedule included items 1 to 16 as substituted by Act 72 of 1981 with effect from 1st October, 1980. Number of other items and goods were added from time to time, to the Schedule. "Industrial machinery" falling under entry 7 is in the Schedule since 1st October, 1980. Later, the Schedule included items 1 to 16 as substituted by Act 72 of 1981 with effect from 1st October, 1980. Number of other items and goods were added from time to time, to the Schedule. "Industrial machinery" falling under entry 7 is in the Schedule since 1st October, 1980. As already stated, sewing machines were not being taxed under entry 7 treating them and classifying them as "industrial machinery", under entry 7 till the Commissioner issued instructions in the year 1987. The Schedule gives the classification and description of goods on which entry tax is levied. The Schedule gives a clue to the object of the legislature and the scheme of levy. For example : Entry 1. All varieties of textiles, namely, cotton, woollen or artificial silk including rayon or nylon and other man-made or synthetic fabrics, manufactured in mills or power-looms, and hosiery cloth in lengths. Entry 2. Tobacco and its products. Entry 3. Sugar other than sugar-candy. Entry 4. Iron and steel, that is to say, - [as enumerated in : (i) to (xvi)]. Entry 5. Cement. Entry 6. All kinds of paper including carbon paper, blotting, paper, water proof paper, PVC coated paper, ferro paper, etc. (omitted by Act 38 of 1984). Entry 7. Industrial machinery and parts and accessories thereof. Entry 8. Aluminium ingots. Entry 9. Industrial gases other than LPG. Entry 10. Coal and coke (excluding charcoal). Entry 11. All petroleum products, that is to say, - petrol, diesel, crude oil, lubricating oil, transformer oil, brake or clutch fluid, bitumin (asphalt), tar and others but excluding LPG, kerosene and naptha for use in the manufacture of fertilisers. Entry 12. Refrigerators, air-conditioners and parts and accessories thereof. Entry 13. Electrical goods, that is to say, electrically operated motors, fans, geysers, etc. Entry 14. All kinds of automobiles excluding passenger buses, tractors, tractor-trailers and power tillers. Entry 15. All kinds of ores. Entry 16. Jute. "Industrial machinery" is now defined in explanation III to entry 7 inserted by Act 18 of 1989. The said explanation, which is already reproduced earlier in this order clarifies what type of machinery should be classified as "industrial machinery" for the purpose of entry 7, and is self-explanatory. Industrial machinery is understood in common parlance as any contrivance run by mechanical process or automation used in an industry or a factory where manufacture or processing of goods takes place. Industrial machinery is understood in common parlance as any contrivance run by mechanical process or automation used in an industry or a factory where manufacture or processing of goods takes place. The very expression "industrial machinery" connotes the primary use of the machinery in industries and in factories. It is impossible to accept the interpretation put forward by the learned Government Pleader that a tailoring unit where garments are made in a large scale come under industries and the sewing machines used therein are, therefore, industrial machinery. It is too broad and too remote a proposition to accept. What is more surprising is that even after the explanation III was inserted by Act 18 of 1989, which clarifies, what is an "industrial machinery" for the purpose of entry 7, the writ petitions are vehemently opposed. It is not the case of the department that prior to the insertion of the explanation, it must be understood in a different way and sewing machines should, therefore, be taxed under entry 7. But the levy is sought to be supported with reference to the explanation itself. I reject this line of argument as wholly untenable. Apart from what the explanation has purported to explain the dictionary meaning or the technical meaning, "the industry and machinery" have and are understood, may be noticed. Corpus Juris explains, "industry" as an antithesis of "domestic". In Webster's New International Dictionary, "industrial" is defined as one that is employed in a manufacturing industry and produced by employing systematic labour. As per Stroud's Judicial Dictionary, "machinery" implies application of mechanical means and "industry" implies a manufacturing activity. Explanation III to the Schedule for the purpose of entry 7 should be applied by the department even to cases arising before the explanation was inserted. Otherwise, it leads to inconsistent view and discrimination in the matter of levy of tax on similar goods. That the later amendment to a statute should act as a guide in the interpretation of a provision which admits of doubt or debate is a well-settled principle of interpretation. (See Additional Commissioner of Income-tax v. A. L. N. Rao Charitable Trust) [1976] 103 ITR 44 (Kar). Thus, the explanation clarifies and removes, whatever doubt, if there was any, in understanding entry 7 and its scope. (See Additional Commissioner of Income-tax v. A. L. N. Rao Charitable Trust) [1976] 103 ITR 44 (Kar). Thus, the explanation clarifies and removes, whatever doubt, if there was any, in understanding entry 7 and its scope. In the result, and for the reasons stated above, the writ petitions are allowed, and the proposition notices impugned in these writ petitions are quashed. The petitioners are entitled to costs of Rs. 1,000, one set, in the two batches of cases represented by the two counsel - Sri Indrakumar and Sri K. R. Prasad. Writ petitions allowed.