JUDGMENT K. S. PARIPOORNAN, J. - The Revenue is the petitioner herein. The respondent is an assessee under the Kerala General Sales Tax Act, 1963. He is a registered dealer. He is doing business in leather goods, like footwear, suit cases, etc. We are concerned with the assessment year 1985-86. 2. The taxable turnover was fixed by adding 20 per cent. to the conceded taxable turnover for probable omission and suppressions. Amongst others, the Sales Tax Officer assessed the turnover of shoe polish at the general rate. The assessee objected to this. In appeal, the assessment made by the Sales Tax Officer was affirmed. In second appeal before the Sales Tax Appellate Tribunal, the assessee took up the plea that the turnover relating to second sales of shoe polish should have been exempted, since shoe polish will come within entry 72 of the First Schedule to the Kerala General Sales Tax Act. The Appellate Tribunal accepted this plea. It held that the turnover of shoe polish should be exempted, since the sales effected by the assessee is second sales. According to the Tribunal, shoe polish will come within entry 72 of the First Schedule to the Kerala General Sales Tax Act. Aggrieved by the decision of the Tribunal dated November 23, 1990, the Revenue has come up in revision. 3. We heard counsel for the Revenue, Senior Government Pleader Mr. V. C. James. The respondent-assessee was not represented before us. 4. The sole question that arises for consideration is, whether "shoe polish" will come within entry 72 of the First Schedule to the Kerala General Sales Tax Act or not. Entry 72 reads thus : "Dyeing, tanning and colouring materials : 72. Paints, colours, lacquers, varnishes, pigments, polishes, indigo, enamel, putty, bale oil, turpentine oil and thinners." The dictionary meaning of the word "polish" is, to make smooth and glossy by rubbing; to bring to a finished state; to impart culture and refinement to (Chambers 20th Century Dictionary, New Edition 1984, page 993). The Concise Oxford Dictionary, New Edition, page 921 gives the following meaning to the word "polish" : "Make or become smooth or glossy by rubbing. A substance used for polishing, etc." 5. Liberally construed, shoe polish may be a substance used for polishing and to make the surface smooth. The Concise Oxford Dictionary, New Edition, page 921 gives the following meaning to the word "polish" : "Make or become smooth or glossy by rubbing. A substance used for polishing, etc." 5. Liberally construed, shoe polish may be a substance used for polishing and to make the surface smooth. But the question is, whether it will be taken in by entry 72 of the First Schedule to the Kerala General Sales Tax Act ? The heading before the relevant entry is "dyeing, tanning and colouring materials". Beneath the said heading, "paints, colours, lacquers, varnishes, pigments, polishes, indigo, enamel, putty, bale oil, turpentine oil and thinners" are mentioned. The sub-heading or the heading aforesaid provides a clue to understand the meaning of the goods mentioned in entry 72. Viewed in the light of the heading and the context in which the word "polish" is used in entry 72 of the First Schedule to the Kerala General Sales Tax Act, we are of the view that the word "polishes", occurring in entry 72 of the First Schedule to the Kerala General Sales Tax Act, will not take in "shoe polish". It will not be an item of goods similar to paints, colours, lacquers, varnishes, etc. Therefore, we hold that the Sales Tax Appellate Tribunal was in error in holding that the words "shoe polish" will be taken in by the word "polishes" occurring in entry 72 of the First Schedule to the Kerala General Sales Tax Act. In the light of this, the second sales of shoe polish by the respondent-assessee will be taxable, as held by the assessing authority. The order of the Appellate Tribunal is set aside to this extent. The assessing authority will give effect to this decision in the assessment order. T.R.C. is allowed. Petition allowed.