JUDGMENT 1. - This revision petition under Section 15(1) of the Rajasthan Sales Tax Act, 1954 has been directed against the Order of the Rajasthan Sales Tax Tribunal, Ajmer dated December 18, 1991 in Appeal No. l9/91/ST/Sri Ganganagar Viswas Surgical Industries v. ACTO. 2. It arises in the following circumstances: The petitioner carries on the business of manufacture and sale of surgical cotton which is known in the trade circle as 'surgical cotton' or 'cotton wool'. The dispute relates to rate of tax applicable on the 'surgical cotton' manufactured and sold by the petitioner for the period between June 28, 1990 to December 26, 1990, while the assessment was being made for the period April 1, 1990 to December 26, 1990. 3. Under Notification dated March 23, 1989, the rate of sales tax on the sale of various commodities was governed. The relevant Entry No. 13 reads as under: 13. Cotton that is to say, all kinds of cotton (indigenous or imported) in its manufactured or unmanufactured state, whether ginned or unginned, baaled, pressed or otherwise but not including cotton waste. 4. Notification dated March 23, 1989 was superseded by another Notification dated June 27, 1990 in which the relevant corresponding Entry No. 16 reads as under: 16. Cotton, that is to say, all kinds of cotton (indigenous or imported) whether ginned or unginned, baled, pressed or otherwise including cotton waste. 5. The Assessing Authority on the turnover upto June 27, 1990 levied the tax at the rate of 4% under Entry No. 13 in the Notification dated March 23, 1989. However, for the period between June 28, 1990 to December 26, 1990 which was governed by Notification dated June 27, 1990 he was of the opinion that surgical cotton' does not fall in any of the specific Entry under the said Notifications and therefore, he levied the tax under the residuary clause at the general rate of 10% on the turnover of the surgical cotton for that period. 6. This revision petition relates to the question as to under which Entry the commodity 'surgical cotton' or 'absorbent cotton', as the commodity in question is known and marketed, is to be taxed. 7. On appeal, before the Dy. Commissioner (Appeals), the aforesaid levy of tax for the disputed period as stated above, was affirmed at the rate of 10%. 8. This revision petition relates to the question as to under which Entry the commodity 'surgical cotton' or 'absorbent cotton', as the commodity in question is known and marketed, is to be taxed. 7. On appeal, before the Dy. Commissioner (Appeals), the aforesaid levy of tax for the disputed period as stated above, was affirmed at the rate of 10%. 8. On further appeal before the Tribunal, the Tribunal opined that since the date of amendment, the 'surgical cotton' did not fall for taxation in Entry 16 of the Notification dated June 27, 1990. However, it accepted the alternate plea of the assessee that instead of falling in the residuary clause, the 'surgical cotton' would fall within the Entry 55 as pharmaceutical preparations, which reads as under: 55. Medicines, Drugs and all kinds of pharmaceutical preparations excluding 6% goods mentioned at Item No. 71 and reduced the levy of tax on the turnover for the period between June 28, 1990 to December 26, 1990 from 10% to 6%. 9. Aggrieved with the aforesaid Order, the assessee has filed this Revision Petition by raising the following questions of law to be decided: (1) Whether in the facts and circumstances of the case, the learned Tribunal was justified in holding that surgical cotton/absorbent cotton/cotton wool manufactured and sold by the petitioner does not fall within the Entry "Cotton of all kinds" taxable at the rate of 4% but falls under the Entry, relating to "pharmaceutical preparation" taxable at the rate of 6%? (2) Whether in the facts and circumstances of the case, the surgical cotton manufactured and sold by the petitioner is pharmaceutical preparation or not? (3) Whether the deletion of words "manufactured or unmanufactured" in the Entry relating to "cotton" with effect from 27.12.1990 will exclude the surgical cotton sold by the petitioner from the said Entry or not? (4) Any other appropriate question/questions of law may be deemed to be arising out of the said order of the learned Tribunal. 10. As it is apparent that question No. 1 and 3 proposed by the assessee are really part of the question No. l. 11. (4) Any other appropriate question/questions of law may be deemed to be arising out of the said order of the learned Tribunal. 10. As it is apparent that question No. 1 and 3 proposed by the assessee are really part of the question No. l. 11. Coming to the first question, it is to be noticed from the relevant Entry reproduced above under Notifications dated March 23, 1989 and June 27, 1990 that by the latter Notification in the entry relating to tax on the sale of 'cotton', the words 'in its manufacture or unmanufactured state' were deleted and by deleting the word 'not' in the last part of the Entry 'the Cotton Waste' was included within the meaning of 'cotton' for the purposes of tax under the said Entry which was earlier excluded from within the meaning of 'cotton'. 12. The learned Counsel for the petitioner urged that as the Notification has used the words "all kinds of cotton", to explain the meaning of word 'Cotton' by using the word "that is to say", the use of words 'in its manufactured or unmanufactured state' before their deleting in the Notification dated March 23, 1989 was mere surplus age and therefore, by the change brought out vide Notification dated June 27, 1990 no change in the meaning of 'cotton' has been brought out. As there is no dispute between the parties that prior to the commencement of the Notification dated June 27, 1990, the surgical cotton was included in the Entry No. 13, it continued to fall within that Entry. 13. On the other hand, Mr. Dinesh Mehta, learned Counsel for the Revenue contended that the use of word 'that is to say' is usually employed to clarify and fix the meaning of what is to be explained or defined. Term 'cotton' has been suffixed with phrase 'that is to say' followed with other words, defining and Fixing the meaning of term 'cotton' for the purpose of taxability of sales thereof under that Entry. Wider meaning fixed in Notification dated march 23, 1989 by including cotton in its manufactured state cannot be read into the meaning of 'cotton' in Notification dated June 27, 1990 where the words 'in its manufactured or unmanufactured state' has now been omitted after 'all kinds of cotton'. Wider meaning fixed in Notification dated march 23, 1989 by including cotton in its manufactured state cannot be read into the meaning of 'cotton' in Notification dated June 27, 1990 where the words 'in its manufactured or unmanufactured state' has now been omitted after 'all kinds of cotton'. He, therefore, contends that the 'cotton' in its ginned or unginned only has been included in the term 'cotton' for the purpose of tax in Entry 16 of the Notification dated June 27, 1990, and 'surgical cotton', which is undoubtedly neither ginned nor unginned but the manufactured stage of cotton is not included in the said definition. In support of this principal argument, learned Counsel relied on observations made in State of Tamil nadu v. Pyarelal Malhotra, (1976) 37 STC 319 . and Rajasthan Roller Flour Mills Association and Anr. v. State of Rajasthan and Ors. (1993) 91 STC 408 . . 14. It is well known rule of construction of statute that where amending act alters any of the principal statute, the alteration must be taken to mean deliberate. The principle was succinctly stated by Cockburn, C.J. in R. v. Price, (1871) LR 6 QB 411. , as under: ...when the legislature, in legislating in para materia and substituting certain provisions in that Act for those which existed in the earlier statute, has entirely changed the language of the enactment, it must be taken to have done so with some intention and motive. 15. The principle was also enunciated by Privy Councel in D.R. Fraser & Co. Ltd. v. Minister of National Revenue, AIR 1941 P.C. 120 . , as under: .... when an amending Act alters the language of the principal statute, the alteration must be taken to have been made deliberately. 16. The same principle was adheard to by the Supreme Court in Western India Theatres Ltd. v. Municipal Corporation, Poona, AIR 1959 SC 586 . , and State of U.P. v. Malik Zarid Khalid, AIR 1988 SC 132 . 17. There are well known exceptions to the aforesaid general rule as well and change in language may always not be indicative of change in construction. 18. Where words omitted in the latter statute when they were mere surplus age in the section it may not result in change in the construction of that provision. 17. There are well known exceptions to the aforesaid general rule as well and change in language may always not be indicative of change in construction. 18. Where words omitted in the latter statute when they were mere surplus age in the section it may not result in change in the construction of that provision. This principle was applied by Apex Court in Raja Bhanu Pratap Singh v. The Assistant Custodian, E.P., Bahraich, 1966 SC 245. . Likewise, where any addition of words are to clear the meaning where it was already implied or where change is merely change in style in drafting, such change may not justify any change of construction in the amending act from the one already existed. This principle was applied by Apex Court in L.D. Sugar Mills v. Pt. Ram Sarup and Ors., AIR 1957 SC 82 , Madanlal Fakirchand Dudhediya v. S. Changdeo Sugar Mills Ltd., AIR 1962 SC 1543 . Md. Quasim v. Mohd. Samsuddin and Anr., AIR 1964 SC 1699 . and Kajari Lal v. Union of India, AIR 1966 SC 1538 . 19. Keeping in view the aforesaid principles regarding construction of Entry in the Notification providing rate of tax on various commodity on their sale or purchase, the issue may be examined. 20. The principal entry which is to be interpretated in the light of the phraseology used there after is commodity known as 'cotton'. 21. The word 'cotton' has according to its dictionary meaning has been defined to mean in different senses. In one sense it means fibrous-substance covering the cotton seed in other it means articles manufactured by such fibrous substance like cotton yarn, thread, fabric etc. In yet another sense it means cotton plant itself.Oxford Shorter Dictionary defines 'cotton' as under:COTTON: 1. The white fibrous substance which clothes the seeds of the cotton plant used for making cloth and thread, etc. 2. The cotton plant; the genus, also plants collectively, 3. Thread spun from cotton yarn; in full thread, 4. Any fabric made of cotton; cotton fabrics, also cotton garments, 5. A cotton-like down growing on other plants: In Webster's Third New International English Dictionary, 'cotton' has been stated to mean: 1. A soft fibrous usu. white substance that clothes the seeds of various plants esp. Thread spun from cotton yarn; in full thread, 4. Any fabric made of cotton; cotton fabrics, also cotton garments, 5. A cotton-like down growing on other plants: In Webster's Third New International English Dictionary, 'cotton' has been stated to mean: 1. A soft fibrous usu. white substance that clothes the seeds of various plants esp. of the genus Gossypium, is composed of unicelular hairs forming fine twisted fibers from 1/2 inch to over 2 inches long when mature, and is used extensively in the making of threads, yams and fabrics, 2. any plant of the genus Gossypium characterised by an errect and freely branching habit, alternate lobed leaves, and large creamy white or yellow flowers that soon turn red and are subtended by a cup-shaped involucre and produce a capsular fruit that bursts open when ripe there by exposing the seeds and attached hairs, 22. According to Random House Dictionary of English Language, 'cotton' means: ' 1. a soft, white, downy substance consisting of the hairs of fibers attached to the seeds of malvaceous plants of the genus Gossypium, used in making fabrics, thread, wadding etc., 2. the plant itself, having an upright manner of growth, spreading branches, and broad, lobed leaves, 3. such plants collectively as a cultivated Crop, 4. cloth, thread, a garment, etc., of cotton, 5. any soft, downy substance resembling cotton, but growing on some other plant, In Chambers Twentieth Century Dictionary 'cotton' means: 1. a soft substance like fine wool, the long hairs covering the seeds of the cotton plant: the plantit self, individually or collectively; yarn or cloth made to cotton, made of cotton, 23. From the aforesaid, it is clear that according to dictionary meaning primarily 'cotton' means cotton in the form of fibrous substance around the seeds which is grown on a plaint individually; or in a wider sense it means collectively cotton, cotton seed as well as the articles manufactured out of it known as yarn, thread or cloth etc. In yet more extended meaning it also includes: the plant itself. 24. Obviously, the cotton in its all grammatical variation for the purpose of interpretation in the Entry in the two Notifications did not include the cotton plant and cotton seed separated from cotton. In yet more extended meaning it also includes: the plant itself. 24. Obviously, the cotton in its all grammatical variation for the purpose of interpretation in the Entry in the two Notifications did not include the cotton plant and cotton seed separated from cotton. It also does not include to mean cotton in all its grammatical variant meaning but includes all kinds of cotton falling in one of the general meaning which can be given to keeping in view its ordinary common parlance meaning. Obviously cotton yarns, thread or fabrics made from raw cotton, are not commodities in ordinary commercial parlance known as cotton by trading community in the context of Sales Tax, but is referable to its primary meaning of 'fibrous substance' which clothes the seeds of cotton plants. So soon it looses its identity as fibrous substance it goes out of the scope of entry 'cotton'. 25. It may be noticed that even in the unamended entry under Notification dated August 23, 1989, the words used were all kinds of cotton 'in its manufactured or unmanufactured state'. Use of words 'in manufactured, state' carried within it meaning that cotton which remained substantially a fibrous substance after undergoing manufactured process. But still it could not include articles manufactured from fibrous substance known as cotton, but loosing its character or fibrous substance. The use of word in its manufactured state is pregnant with the meaning that only such manufactured cotton was included within it which retained its character as cotton that is fibrous substance. 26. In this context one may look at the dictionary meaning of absorbent cotton': 27. Random House Dictionary of English Language defined 'absorbent cotton' as "cotton for surgical dressing, cosmetic purposes etc. made by removing the natural wax. 28. According to Webster's Third New International Dictionary 'absorbent cotton' means-cotton made absorbent by chemically freeing it from its fatty matter. 29. 26. In this context one may look at the dictionary meaning of absorbent cotton': 27. Random House Dictionary of English Language defined 'absorbent cotton' as "cotton for surgical dressing, cosmetic purposes etc. made by removing the natural wax. 28. According to Webster's Third New International Dictionary 'absorbent cotton' means-cotton made absorbent by chemically freeing it from its fatty matter. 29. According to British Pharamecutical Codex 1959 absorbent cotton 'is prepared from cotton which consists of epidermal trichomas of seeds of Gossypium herbaceum L. and other cultivated species of Gossypium.' The process of preparations of absorbent cotton has been described as follows: "the seeds are removed mechanically and the trachomes freed from fatty matter by treatment with alkali, are bleached, wasted and mechanically separated to form a fleacy mass of soft white filaments which consist almost entirely of cellulose." in that shape substance continues to be cotton; albeit in its manufactured state, different from raw cotton. 30. The word 'cotton' in the Notification prescribing rates of tax, has been sought to be explained and meaning of it is sought to be fixed by further use of the word "that is to say" soon after the word 'cotton' in the Entry. The significance and effect of the use of word "that is to say" is ordinarily to make clear and fix the meaning of what is to be explained or defined and such words are not used as rule to amplify meaning of the word with which it has been used. 31. In Strouds Judicial Dictionary (Vol. VTH PAGE-2753), the phrase "that is to say" has been defined as under: 1. "that is to say" is the commencement of an ancillary clause which explains the meaning of the principal clause. It has the following properties: (1) it must not be contrary to the principal clause; (2) it must neither increase nor diminish it: (3) but where the principal clause is general in terms it may restrict it. 32. The aforesaid definition of phrase "that is to say" was explained by their Lordships of the Supreme Court in State of Tamil Nadu v. Pyare Lal Malhotra, , as under: Ordinarily, the expression "that is to say" is employed to make clear and fix the meaning of what is to be explained or defined. 32. The aforesaid definition of phrase "that is to say" was explained by their Lordships of the Supreme Court in State of Tamil Nadu v. Pyare Lal Malhotra, , as under: Ordinarily, the expression "that is to say" is employed to make clear and fix the meaning of what is to be explained or defined. Such words are not used, as a rule, to amplify a meaning while removing a possible doubt for which purpose the word "includes" is generally employed. 33. This view was reiterated in Rajasthan Roller Flour Mills Association and Anr. v. State of Rajasthan and Ors. . (2). 34. In Notification dated March 23, 1989, the word 'cotton' of all kinds in its manufactured or unmanufactured state. 35. However, the aforesaid principle is not of universal application. It depends on the context in which the words "that is to say" are used. In State of Tamil Nadu's (1), the position was made amply clear when their Lordships after referring the decision of Meghraj v. Allah Rakhia, AIR 1947 P.C. 72 . , observed as under: ' .. ..depending upon the context of the words "that is to say", this expression may be followed by illustrative instances. In Megh Raj v. Allaha Rakha. , the words "that is to says", with reference to a general category "land" were held to introduce, "the most general concept" when followed, inter alia, by the words "right in or over land". We think that the precise weaning of the words "that is to say" must vary with the context. 36. It may be noticed that in Pyarelal Malhotra's case (1), as well as in Rajasthan Roller Flour Mills case (2), their Lordships were concerned with interpreting entries made in Section 14 of the Central Sales Tax, where the words "that is to say" were followed with enumeration of various kind of goods on the given list. 37. In Pyarelal's case. (1), their Lordships were concerned with Clause 14(iv) which relates to commodity 'iron and steel'. The said commodity too was suffixed by word "that is to say" followed by 16 categories of different goods made of 'iron and steel' which were to come within the meaning of word 'iron and steel'. 38. Likewise in Rajasthan Roller Flour Mills case. (1), their Lordships were concerned with Clause 14(iv) which relates to commodity 'iron and steel'. The said commodity too was suffixed by word "that is to say" followed by 16 categories of different goods made of 'iron and steel' which were to come within the meaning of word 'iron and steel'. 38. Likewise in Rajasthan Roller Flour Mills case. (2), their Lordships were concerned with the interpretation of Sub-clause (iii) (i) of Section 14 dealing with 'fresh food' followed with ten items, therein. 39. In the present case, the Entry 13 as well as Entry 16 in the two Notifications in question dealt with cotton. The term cotton is not qualified with 'raw' so as to give it restrictive meaning to mean cotton in its natural form. To explain the term 'cotton' it was followed with "that is to: say". The word "that is to say" was followed with 'all kinds of cotton'. By use of words 'all kinds of cotton' as the specified item in the schedule providing rate of sales tax in the context must mean that word "that is to say" was used to give the expression 'cotton' a wide scope to include all kinds of cotton used in, its generic sense of 'fabrous substance' with or freed from seeds. If perceived in the sense the use of the words in its manufactured or unmanufactured state whether ginned or unginned was only to emphasis the amplitute of the variety of term 'cotton' to fall within the ambit of entry in question and to make it clear that cotton is not restrictive to in its raw form and the use of illustrative word was merely surplusage to elaborate and emphasise the sense in which the word 'cotton' has been used for the purpose of levy of sales tax. 40. In this connection one important factor to note is that in entry 32 of concurrent list of VII Schedule of constitution, the expression used 'raw cotton, whether ginned of unginned. . ." in Section 14(ii) of the Central Sales Tax Act, providing for goods of special importance in the course of inter state trade and commerce, the expression used is: Cotton that is to say all kinds of cotton (indiginous or -imported) in its unmanufactured state whether ginned or unginned, baled, pressed or otherwise but not including cotton waste, 41. . ." in Section 14(ii) of the Central Sales Tax Act, providing for goods of special importance in the course of inter state trade and commerce, the expression used is: Cotton that is to say all kinds of cotton (indiginous or -imported) in its unmanufactured state whether ginned or unginned, baled, pressed or otherwise but not including cotton waste, 41. For Cotton fabric and cotton yarn separate entries were made. 42. In both the above expression, the framers of Constitution and the Parliament in unmistakable terms confined the meaning of cotton to cotton in its natural form which has not undergone process of manufactures. To signify this intention in the entry 33 of the concurrent list of VII Schedule, the expression cotton was prefixed with word 'raw'. In the Central Sales Tax Act where prefix raw' was not there to qualify 'cotton', it was made clear by using the word 'in its unmanufactured state'. It was by using these very words, meaning of cotton was confined to its unmanufactured state in the second schedule appended to Tamilnadu General Sales Tax Act, 1959. 43. In this context, it may also be noticed that Under Rajasthan Sales Tax Act, an extended meaning to word 'cotton' has been given since beginning by adopting the language used in General Sales Tax Act ad verbetis by adding the words 'in its manufactured' and unmanufactured state'. In Notification dated March 9, 1969 Item No. 16 read as under: Cotton that is to say all kinds of cotton (ingigenous or imported) in its manufactured or unmanufactured state, whether ginned, or unginned, baled, pressed or otherwise, but not including cotton waste. 44. The expression continued to be used in successive notifications dated July 1, 1975 (Item No. 2), March 8, 1988 (Item No. 11) and March 23, 1989 (Item No. 13). In all these Notifications, cotton was to exclude cotton waste. In the Notification dated June 27, 1990, the exclusion of cotton waste from the definition of 'cotton' was removed. Thus departure from giving the 'cotton' its restricted meaning as given under the Central Sales Tax Act as declared goods is manifest since beginning. It is significant, while including the cotton waste within the meaning of word 'cotton' under the Notifications in question, the authority was not confining the meaning of cotton as declared goods under Section 14 of the Central Sales Tax Act. It is significant, while including the cotton waste within the meaning of word 'cotton' under the Notifications in question, the authority was not confining the meaning of cotton as declared goods under Section 14 of the Central Sales Tax Act. if viewed in this light, it can reasonably be informed that by omitting both expressions 'in its manufactured or unmanufactured state' the omission was not delibarate to give it the restricted meaning as the declared goods but was intended to omit those words which were treated surplusage. 45. In this connection it may be relevant to note that in somewhat similar circumstances the Bombay High Court in Commissioner of Sales Tax, Maharashtra State, Bombay v. Fairdeal Corporation Ltd., 1962 13 STC 750 . ., in which the question arose for consideration of their Lordship was whether absorbent cotton wool or surgical cotton is not 'raw cotton (whether ginned or unginned)' within the meaning of Item-I schedule B of the Bombay Sales Tax Act. The contention was raised that even in its state as surgical cotton the substance continued to be cotton and comes within the meaning of cotton. The contention of the Advocate General that word 'cotton' by itself would mean cotton in unadulterated or unchanged form, and therefore, so long as the commodity of the substance remains nothing else but cotton, it is possible to urge that substance continues to be cotton, but the word cotton is qualified by 'use of word' 'raw' which according to dictionary meaning is in natural or nearly natural form, was accepted and the respondent's contention was rejected by saying: In our opinion, the submissions urged by the learned Advocate General are substantial and must be upheld. The Tribunal has been influenced by the fact that cotton wool is described as raw cotton by the dictionaries. But the article with which we are concerned is not cotton wool. It is absorbent cotton wool or surgical cotton wool, which is cotton wool or raw cotton, which has been subjected to certain processes of preparation and is a finished or prepared product from cotton wool as the raw material. Raw cotton after it is changed into absorbent cotton wool would neither in its appearance, nor in its tests and qualities give the same results and effects as the raw cotton, which has not undergone the same process. Raw cotton after it is changed into absorbent cotton wool would neither in its appearance, nor in its tests and qualities give the same results and effects as the raw cotton, which has not undergone the same process. The argument advanced by the learned Advocate for the respondents that 'cotton' so long as it retains essentially its substance as cotton, is included within the entry No. I of Schedule B, cannot be accepted entry No. I of Schedule B, cannot be accepted in view of the language used in the entry. It is only cotton which can qualify to the description of being raw cotton either in the ginned or unginned state that can come within the said entry." 46. Looking to language used in the notification, which neither qualifies word cotton prefixing it with word 'raw' nor restricts its meaning to its unmanufactured state', in my opinion even according to Us plain meaning 'all kinds of cotton' will include within it any article which in substance remains 'cotton' as fibrous substance, whether it is in manufactured state or unmanufactured state. 47. Viewed from this point, in my opinion by deleting the words 'in its manufactured or unmanufactured state' in the Notification dated June 27, 1990 has not resulted in any change in meaning of the entry as it was provided in Item No. 13 of Notification dated March 23, 1989 corresponding to Item No. 16 of Notification dated June 27, 1990. 48. The question can be looked from another angle. Vis a vis residuary entry 'cotton' is a specific entry relating to term cotton generally. Cotton wool or surgical cotton, unless it comes into any other specific entry concerning it or concerning genre of goods or commodity to which it belongs, surgical cotton can reasonably come within the general term 'cotton' as it is cotton in its manufactured state meant for specified use including for surgical dressing. If a commodity can reasonably be related to any of the specific entry in the schedule prescribing rate of tax it cannot be taxed under the residuary clause of unspecified items. 49. At any rate as per the well known principle that if two construction of a taxing provision are reasonably possible then that interpretation must be accepted which goes in favour of the circumstances which principle has been reiterated recently in Union of India v. Justice S.S. Sandhawalia (Retd.) and Ors. 49. At any rate as per the well known principle that if two construction of a taxing provision are reasonably possible then that interpretation must be accepted which goes in favour of the circumstances which principle has been reiterated recently in Union of India v. Justice S.S. Sandhawalia (Retd.) and Ors. 1994 JT (1) 62. . 50. There is no dispute between the parties that in Entry No. 13 of Notification dated March 23, 1989, the surgical cotton was included in the expression 'cotton that is to say all kinds of cotton'. 51. The view which I have taken above, I am unable to accept the contention of the learned Counsel for the respondent that 'cotton' in Entry No. 16 of Notification dated June 27, 1990 would mean only ginned and unginned cotton and not other cotton. This is clearly so because 'the ginned and unginned cotton' has not followed the words 'that is to say' as enumeration of the 'all kinds of cotton', but has followed all kinds of cotton-as illustrative clause prefixed by word 'whether. 52. I am also of the opinion that amendment or the change in phraseology in the Notification providing rate of sales tax by Notification dated June 27, 1990 replacing the earlier Notification dated March 23, 1989 has not resulted in any alteration in the meaning of the term 'cotton' as a taxable commodity except to further expand it to include cotton waste also. 53. This brings me to the next question whether the surgical cotton falls within Entry 58 as pharamceutical preparation. 54. This question survives because the general rule of construction demands that if a commodity is covered by a general entry of common genre and a specific entry for the purpose of such schedule the commodity must be held to be falling under the specific entry. The contention of the learned Counsel for the Revenue in this connection was that as there is a specific entry in the schedule prescribing rate of tax on pharmaceutical preparations under which 'surgical cotton' comes, it cannot be taxed under entry 16 for the period in question as cotton because in the context, the term 'cotton' is a general entry for the purpose of sales tax and 'pharmaceutical preparation' is a specific entry. It appears that this alternative argument, which was adopted by assessee before the Tribunal to reduce the tax liability from 10% to 6%, if not to 4% has been adopted by revenue before this Court to sustain the tax liability at least to 6% if not at 10%. 55. The learned Counsel, for this principle has relied on Sri Ram Products v. The State of Tamil Nadu, 52 STC 187. . 56. Having carefully considered the contention of the learned Counsel and perused the decision relied on by him, I am of the opinion that this question must be answered in the negative. 57. The word 'Pharamceutical preparation' in its usual meaning means pertaining to or engaged in pharmacy: relating to the preparation, use, or sale of medicinal drugs. 58. The word 'Pharmacy' has been defined in the Shorter Oxford English Dictionary as the use or administration of drugs or medicines: the art or practice of collecting, preparing, and dispensing drugs, medicinally, the compounding of medicines; the occupation of a druggist or pharmaceutical chemist. 59. It cannot be said that surgical cotton or absorbent cotton or cotton wool in any sense of meaning pertains to 'preparation of medicinally drugs' for use or sale. It is dressing material used as an ancillary article in the cases of surgery. I am fortified in my above view by a decision of the Allahabad High Court in Commissioner of Sales Tax v. Indo Pharma Agencies 1980 U.P.T.C. 420. , wherein Justice R.M. Sahai, as he then was considering the entry 'medicine and pharmaceutical preparation including unclassified item' under U.P. Sales Tax Act, held as under: According to dictionaries, therefore, the word is confined to preparations in relation to drugs. Surgical cotton cannot be covered in it as it is not sold or used as medicine. The finding of popular meaning does not appear to be based on material on record. As neither on technical meaning nor in popular meaning surgical cotton can be said to be recovered in pharmaceutical preparation. 60. I am in respectful agreement with the above view. 61. The decision relied on by the learned Counsel for the respondents in this connection is of little assistance. 62. As neither on technical meaning nor in popular meaning surgical cotton can be said to be recovered in pharmaceutical preparation. 60. I am in respectful agreement with the above view. 61. The decision relied on by the learned Counsel for the respondents in this connection is of little assistance. 62. In Sri Ram Product's case (2), the question arose in the context of the Entry 95 of the first schedule attached to the Tamil Nadu General Sales Tax Act, 1959 which reads as under: Drugs, patent or proprietary medicines as defined in Section 3 of the Drugs and Cosmetics Act, 1940 (Central Act XXIII of 1940), or medicinal mixtures or compounds, the components of which have not already suffered tax, but excluding Arishtams or Asavas and including surgical dressing. 63. It would be noticed that the entry in question specifically referred to the word 'surgical dressing' which undoubtedly a surgical cotton or the absorbent cotton, which is the commodity in question, is and generally and commercially known as a commodity used in surgical dressing. 64. It may also be noticed that Item 2 of the second schedule of the Tamilnadu General Sales Tax confining the meaning of cotton to all kinds of cotton 'in its unmanufactured state.' it was a clear indication that the cotton in its manufactured state in any form did not fall within the general entry of cotton. This also, can be safely stated without the fear of contradiction that the surgical cotton is a specie of cotton in its manufactured state. Therefore, the decision of the Madras High Court given in the context of the entries of the Tamil Nadu Sales which were different from the entries of the Rajasthan Sales Tax, with which I am concerned is of no assistance to the case of Revenue. 65. It may also be noticed in this context that under the Notification at hand as discussed above the entry is not confined to raw cotton and the expression 'all kinds of cotton' has not been restricted to the cotton in its unmanufactured state as was in the Tamil Nadu General Sales Tax Act. That being the position, the term 'all kinds of cotton' is wide enough to include in its ambit cotton in its manufactured stale or unmanufactured state and is not covered by the entry No. 55 Pharmaceutical preparation. That being the position, the term 'all kinds of cotton' is wide enough to include in its ambit cotton in its manufactured stale or unmanufactured state and is not covered by the entry No. 55 Pharmaceutical preparation. As the surgical cotton can reasonably be connected to entry 16 of the Notification dated June 27, 1990, the same cannot be taxed at general rates under residuary item also. 66. In view of the aforesaid conclusion, the revision petition is allowed and it is held that for the period from June 27, 1990 to December 26, 1990, the surgical cotton was taxable under Item No. 16 of the Notification dated June 27, 1990 as cotton @ 4%. As such the assessment order be accordingly modified and consequent relief may be given to the petitioner. 67. There will be no order as to costs.Revision Allowed. *******