H. L. DATTU, J. ( 1 ) IN view of the identical nature of facts, grounds urged and the issues involved in these writ petitions, all these petitions are clubbed together, heard and disposed of by a common order. Reliefs sought in these petitions is to : (a) quash circular instruction dated August 10, 1989 issued by Commissioner of Commercial taxes, Bangalore (b) quash pre-assessment notices for the respective assessment years (c) quash the orders of assessments framed in the respective assessment years by the concerned assessing authorities. ( 2 ) FACTS in nutshell are : Petitioners are dealers in purchase and sale of bamboo sticks and other raw materials required for manufacture of agarbathis. Petitioners had claimed exemption in respect of sale of "bamboo sticks" for the assessment years in question on the basis of notification issued by the State Government exercising its powers under section 8a of the karnataka Sales Tax Act, 1957 (for short "the State Act" ). The said claim has been negatived by the assessing authorities, and according to the petitioners, solely basing on the circular instruction of the Commissioner of Commercial Taxes. In some of the petitions, petitioners have questioned the correctness or otherwise of the pre-assessment notices, and in some other petitions, the orders of assessment for the respective assessment years. This Court by an interim order had stayed all further proceedings pursuant to the notices and the orders of assessment. ( 3 ) ONE and the only question that has to be decided in these petitions is whether "bamboo-sticks" are the same as bamboo splits, or whether bamboo sticks are the products of bamboo. For the purpose of deciding this issue, it would be useful to refer to certain entries in the schedule, circular instructions issued by Commissioner of Commercial Taxes and the exemption notification of the State Government. Goods "bamboo" finds a place under entry 1, Part B of the Second Schedule to the Act. The said entry reads as under "part B sl. Description of goods Rate of tax No. 1 Bamboo (whether whole or split) Six per cent. " It should be mentioned here that this entry was originally entry 192 of the second Schedule to the Act and it read as under : 192 Firewood, charcoal and bamboo (whether whole or split) it should be mentioned here, that this entry was introduced with effect from April 1, 1986. " It should be mentioned here that this entry was originally entry 192 of the second Schedule to the Act and it read as under : 192 Firewood, charcoal and bamboo (whether whole or split) it should be mentioned here, that this entry was introduced with effect from April 1, 1986. ( 4 ) NOW, come to the clarification issued by Commissioner of Commercial Taxes under section 34 (2) of the Act reads as under : "bamboo sticks - Not a product of cane and bamboo (CLR. CR. 171/89-90 dated August 10, 1989)" ( 5 ) THE State Government has issued a notification under section 8a of the Act in No. FD 107 csi 89 (XII) dated March 31, 1989 exempting "products of cane and bamboo but not including furniture". ( 6 ) THE word "bamboo as a whole or split" is not defined in the Act. According to the dictionary meaning, bamboo is a giant grass noted for the usefulness of its hollow woody stem. Bamboos are distantly related to wheat, oats and barely. But unlike these crop grasses, most bamboos are of giant size. Some may stand as much as 120 ft. (37 metres) high and have stems 1 foot (30 centimetres) in diameter. Bamboo stems are used as fishing poles and in ornamental screens, cooking utensils, tools, baskets and building material. Meaning attached to the word "split" in Webster's dictionary is as under : "split v. t. to cut lengthwise; to cleave; to separate. . . . . . . . . The entry 1 of Part B of the Second Schedule to the Act speaks of bamboo as a whole and bamboo in split in form. Entry does not envisage bamboo product. The word "split" in entry is as opposed to the word "whole" with reference to bamboo. A split bamboo continues to be bamboo though not a whole bamboo when the Legislature uses the expression split-bamboo, according to me a bamboo cut lengthwise, which can be used for the manufacture of cooking utensils, ornamental screens, baskets, furnitures, etc. Levy under section 5 (3) (a) of the Act is attracted whenever there is sale of bamboo either in "whole form" or "split form" and not otherwise. Levy under section 5 (3) (a) of the Act is attracted whenever there is sale of bamboo either in "whole form" or "split form" and not otherwise. ( 7 ) THE State Government exercising its powers under section 8a of the Act has issued a notification in No. FD 107 CSI 89 (XII) dated March 31, 1989 exempting products of cane and bamboo but not including furniture. Precise question for an answer before this Court is whether agarbathi bamboo sticks are products of bamboo or whether they fall within the expression "bamboo splits". Exemption notification speaks of product of bamboo. To avail general exemption in rate of tax, the goods must be "bamboo product". According to the Webster's dictionary, the word "product" is defined as : "that which is produced; a result; the result of multiplication; manufactured, etc. ". From the aforesaid meaning of the word "product", it is at once clear that to be a product, it must be something that is brought forth either naturally or as a result of effort and work. Apart from the dictionary meaning, even as understood by any layman according to the dictates of common sense, it could only mean a commodity or a thing which has come into existence either naturally or as a result of effort and work. The expression that is used in the notification is of general character and it should be understood in the sense in which every person understands that expression and it is not necessary to give a rigid or artificial meaning. The words "bamboo product" should be understood in its common parlance and if it is so understood, it cannot be said "bamboo agarbathi sticks" would not fall within the expression "bamboo products". Popular meaning of the expression "bamboo agarbathi sticks" are those small and thin sticks which are prepared by human effort out of bamboo splits. By no stretch of imagination it can be said "bamboo splits" and "bamboo agarbathi sticks" which are produced by human effort and labour are one and the same. The word "product" does not have a restricted meaning. It is therefore necessary to give a meaning which would effectuate the purpose and object of exemption notification. In my view "bamboo splits" are nothing but raw materials to the production of product called "bamboo agarbathi sticks". The word "product" does not have a restricted meaning. It is therefore necessary to give a meaning which would effectuate the purpose and object of exemption notification. In my view "bamboo splits" are nothing but raw materials to the production of product called "bamboo agarbathi sticks". If this is the only way to understand the expression "bamboo products", then the view expressed by the Commissioner of Commercial taxes in its Circular CLR. CR. 171/89-90 dated August 10, 1989 is wholly opposed to dictates of common sense of layman and also as understood in commercial trade circles and further in my view the head of the department has tried to understand the words "bamboo agarbathi sticks" in a narrow sense to deprive the dealers of "agarbathi sticks" from the benefit under the notification by attempting to discard the popular meaning and by giving a highly technical and rigid meaning. ( 8 ) SRIYUTHS S. Narayan, K. S. Ramabhadran, A. Satyanarayan, learned counsels appearing for petitioners strongly rely upon the decision of the honourable Supreme Court in the case of collector of Central Excise v. Protein Products of India Ltd. [1989] 74 STC 98 to drive home the meaning of the word "product" to say it means anything produced or obtained. In the said case honourable Supreme Court while considering whether ossein and gelatine manufactured by the dealer from bones are exempt under the notification issued under the Central Excises and Salt act, 1944. While explaining this aspect of the matter, the honourable Supreme Court was pleased to explain the meaning of the expression "product". "the word 'product' is defined in Webster's Comprehensive Dictionary as anything produced or obtained as a result of some operation or work. The expression 'bone products' therefore, merely means anything produced or obtained from bones. Whether such derivation is by a simple physical process or by a chemical reaction would seem to make no difference to the end-product. Butter milk, for instance, does not cease to be a milk product merely because a chemical process is involved in the transformation. The ossein and gelatine manufactured by the respondent can, without straining the expression used in the notification, be described as bone products. " applying the principles evolved by the honourable Supreme Court to the facts of the present petitions, it may be safely stated that "bamboo agarbathi sticks" are the products of bamboo. The ossein and gelatine manufactured by the respondent can, without straining the expression used in the notification, be described as bone products. " applying the principles evolved by the honourable Supreme Court to the facts of the present petitions, it may be safely stated that "bamboo agarbathi sticks" are the products of bamboo. If this is the only interpretation possible, then certainly the exemption notification issued by the state Government would come to the aid of writ petitioners and as such they would be entitled to total exemption from levy of tax under the charging provisions. ( 9 ) HOWEVER, Smt. Vidya, learned counsel appearing for the Revenue, would seriously contend before me that "bamboo agarbathi sticks" are nothing but "bamboo splits" and if so understood the commodity in question would come under entry 1 of Part B of the Second Schedule to the act. I am unable to accept the stand of the learned Government Pleader and further I cannot persuade myself to accept the narrow meaning which the learned Government Pleader wants me to adopt to interpret the word "product". As stated earlier by me, a product is a thing produced and as such "bamboo agarbathi sticks" that are sold by the petitioners are the products of "whole bamboo" or "split bamboo". In the view that I have taken it cannot be conceived agarbathi sticks as split bamboo, as understood by Commissioner of Commercial Taxes, whose understanding has been followed by the assessing authorities to issue pre-assessment notices and to frame assessments for the respective assessment years. ( 10 ) IN the light of issues discussed as above and applying the ratio laid down by the Supreme court, I am of the view that the petitioners are entitled to the reliefs in question. ( 11 ) THE learned counsel for the petitioners also contended that the notification dated March 31, 1989 is a beneficial notification and the same has to be liberally construed and they also contended that any other interpretation which would render the exemption notification redundant should not be accepted. This aspect need not be gone into in these writ petitions for the reason I have already held that the popular, perhaps the literal meaning of the expression "bamboo product" used in the notification dated March 31, 1989 would include bamboo agarbathi sticks. This aspect need not be gone into in these writ petitions for the reason I have already held that the popular, perhaps the literal meaning of the expression "bamboo product" used in the notification dated March 31, 1989 would include bamboo agarbathi sticks. ( 12 ) IN view of the foregoing, I hold that the dealers are not liable to pay sales tax on the sale turnover of "bamboo agarbathi sticks" under section 5 (3) (a) of the Act and I further hold "bamboo agarbathi sticks" are "bamboo products" and they are entitled to the benefit of the notification of the State Government in No. FD 107 CSI 89 (XII) dated March 31, 1989. Consequently, contrary view of the Commissioner of Commercial Taxes expressed in Circular no. CLR. CR. 171/89-90 dated August 10, 1989 is liable to be quashed and accordingly a writ of certiorari is issued to quash the impugned circular dated August 10, 1989. Accordingly a direction is issued to the respective assessing authorities wherever pre-assessment notices are questioned to withdraw the same and issue fresh notices in accordance with law and in accordance with the observations made by this Court and further orders of assessments framed by the respective assessing authorities are quashed with liberty to redo the assessments in accordance with law and in accordance with the observations made in these writ petitions. In the result, the writ petitions are allowed as indicated above. There shall be no order as to costs.