JUDGMENT V. V. KAMAT, J. These are the four tax revision cases requiring us to exercise powers under section 41 of the Kerala General Sales Tax Act, 1963 read with rule 41(1) of the Kerala General Sales Tax Rules, 1963, which is in pursuance of section 9(2) of the Central Sales Tax Act, 1956, enacting the applicability of general sales tax law of this State. 2. In all these four revision cases the assessment years 1985-86, 1986-87, 1988-89 and 1987-88 respectively are involved. Although all these four petitions relate to the question of assessment of four different and independent assessment years, they raise the solitary question. The said question relates to the applicability of section 8(2A) of the Act. To be precise the question would be relation to the situation relating to sale and consequent taxation, if it is exemption from tax generally, under the sales tax law of the State of Kerala whether, still it could be considered to be taxable under the Central Sales Tax Act, 1956. Therefore it is more than obvious that the situation gets governed by the statutory provision of section 8(2A) of the Central Sales Tax Act, 1956. In the said provision, the tax even if may be payable under the Central Sales Tax Act and it relates to the sale of any goods which is, under the sales tax of this State of Kerala is exempt generally, the tax payable shall be nil. 3. The above contention has been taken up that the petitioner-assessee is exempt from tax under the Kerala General Sales Tax Act and consequently therefore there cannot be a levy of tax by virtue of provisions of section 8(2A) of the Central Sales Tax Act, 1956. 4. Before the first appellate authority - the Appellate Assistant Commissioner of Agricultural Income-tax and Sales Tax, Kannur, it was contended that the commodity or the goods would be coir (i.e., coconut fibre used for ropes, matting, etc.). It was further submitted that coir including coir yarn has been exempted from tax payable under the Kerala General Sales Tax Act, 1963 and therefore in view of the above position, the inter-State sales in question would also be governed by the said situation of exemption, obviously under section 8(2A) of the Central Sales tax Act, 1956. 5. It was further submitted that coir including coir yarn has been exempted from tax payable under the Kerala General Sales Tax Act, 1963 and therefore in view of the above position, the inter-State sales in question would also be governed by the said situation of exemption, obviously under section 8(2A) of the Central Sales tax Act, 1956. 5. The first appellate authority did not dispute this position of applicability of section 8(2A) of the Central Act in the event of the commodity in question as exempt under the State sales tax law - Kerala General Sales Tax Act, 1963. 6. The assessee is sought to be taxed under the Central Sales Tax Act with regard to the sale of coconut fibre. It was contended that coir means (in Malayalam). This was to contend that it would comprehend coir fibre. Reliance was also placed on the dictionary meanings of the word coir. This was with reference to standing dictionary meanings - Chambers and Oxford to mean that coir means coconut fibre. It was also contended that if there is any contrary view to urge that coir will not include any coir fibre it would be upon him to state what exactly is meant by the term coir. Reliance was also placed on the Government Notification - S.R.O. No. 319 of 1984 issued by the State Government under section 10 of the said Act. This was to contend that the very language of the said notification would show that the State Government considered coir to mean and include coir fibre also. In order to support the continued intention of the State Government to have a comprehensive approach to understand coir to include coir fibre, reliance was also placed on the further notification - S.R.O. No. 432 of 1991 also issued by the State Government under section 10 of the Kerala General Sales Tax Act, 1963. This notification exempts coir fibre from tax. To emphasize the situation further in the context entry No. 49 of the First Schedule to the State Act, 1963 which was in force on and from July 1,1987, as also entry No. 98 which was in force up to June 30, 1987, was relied upon to buttress the said submission. Relying on the two entries it was submitted that the State Government understood coconut fibre, coir yarn, coir products and bonded fibre fabrics of coir to be synonymous. 7. Relying on the two entries it was submitted that the State Government understood coconut fibre, coir yarn, coir products and bonded fibre fabrics of coir to be synonymous. 7. In the light of these aspects, unfortunately the first appellate authority emphasized the fact that the appellant is dealing in coconut fibre which cannot be understood to be synonymous with the entries and notifications referred to above. It was held that the assessee could not be understood to be entitled to any exemption and consequent advantage of section 8(2A) of the Act. 8. Further travel of the proceedings before the Kerala Sales Tax Appellate Tribunal, Additional Bench, Kozhikode, resulted in the endorsement with a finding that "one cannot say that coconut fibre is the same commodity as coir". The Appellate Tribunal has referred to the entries and the notifications under the Kerala General Sales Tax Act 1963. The Appellate Tribunal has not disputed the position that in the event of exemption of tax generally under the State Act, the benefit of such exemption should correspondingly come under the Central Act also. In fact the Tribunal has reinforced this statutory provision by relying on the decision of the apex Court in Hindustan Paper Corporation Ltd. v. State of Kerala [1993] 89 STC 473 and on the assumption of this undisputed position, the Tribunal has proceeded to consider as to whether "coconut fibre" could be regarded as the same commodity with reference to the entries and notifications under the State Act. As stated above, the Tribunal, at the end has reached the conclusion that one cannot say that the coconut fibre is the same commodity as coir. 9. Before us it is not the situation that the petitioner-assessee has been taxed under the Kerala General Sales Tax Act, 1963. This is because it was his positive contention that the commodity sought to be taxed under the Central Sales Tax Act, 1956 is exempt under the State Act, justifiably covering the situation under section 8(2A) of the Central Sales Tax Act, 1956. 10. In the context of chronology of time it will have to be seen that entry No. 98 of the First Schedule to the Kerala General Sales Tax Act was to governing the situation up to June 30, 1987 and about this there is no dispute. The said entry is reproduced hereinbelow : ------------------------------------------------------------------------ Sl. 10. In the context of chronology of time it will have to be seen that entry No. 98 of the First Schedule to the Kerala General Sales Tax Act was to governing the situation up to June 30, 1987 and about this there is no dispute. The said entry is reproduced hereinbelow : ------------------------------------------------------------------------ Sl. Description of goods Point of levy Rate of No. tax ------------------------------------------------------------------------ 98 Coconut fibre, coir yarn, At the point of last 2% coir products, and bonded purchase in the State fibre fabrics of coir. by a dealer who is liable to tax under section 5. ------------------------------------------------------------------------ The said entry provides aid to know how the coconut products are to be understood under the State Act. Coconut fibre, coir yarn, coir products and bonded fibre fabrics of coir are all clubbed together in this entry, obviously showing their synonymity in the process of a commodity liable to be taxed under the State Act up to June 30, 1987. It is appropriate to note that 2 per cent is the rate and by reason thereof under section 8(2A) exemption is available in regard thereto. 11. Thereafter on and from July 1, 1987 the situation is replaced by entry No. 49. It is reproduced as hereunder : "49 Coconut fibre, coir yarn, At the point of last 2%" coir products, and bonded purchase in the State fibre fabrics of coir. by a dealer who is liable to tax under section 5. This would also show that the contents of the situation get continued even after July 1, 1987 in the similar way to strengthen the legislative intent that coconut fibre, coir yarn, coir products and bonded fibre fabrics of coir have continued to be understood on the basis of synonimity in regard thereto and by reason thereof also the rate being 2 per cent continued, the situation is of exemption under section 8(2A) of the Central Sales Tax Act, 1956. 12. In addition thereto there are two Government notifications. In the first instance comes the Government Notification G.O.Ms. No. 62/84/TD dated March 30, 1984 (S.R.O. No. 319 of 1984, to make it clear that coir is understood to include coir yarn. The said notification along with the explanatory note is as follows : "Purchase of coir including coir yarn - Exemption (Kerala) Notification G.O.Ms. No. 62/84/TD dated the 30th March, 1984. S.R.O. No. 319/84. No. 62/84/TD dated March 30, 1984 (S.R.O. No. 319 of 1984, to make it clear that coir is understood to include coir yarn. The said notification along with the explanatory note is as follows : "Purchase of coir including coir yarn - Exemption (Kerala) Notification G.O.Ms. No. 62/84/TD dated the 30th March, 1984. S.R.O. No. 319/84. - In exercise of the powers conferred by section 10 of the Kerala General Sales Tax Act, 1963 (15 of 1963), the Government of Kerala, having considered it necessary in the public interest so to do, hereby make an exemption in respect of the tax payable under the said Act on the purchase of coir including coir yarn. This notification shall come into force with effect from the 1st day of April, 1984. Explanatory Note. - (This does not form part of the notification, but is intended to indicate the general purport.) Government consider that for the development of coir industry in the State sales tax on coir should be exempted. This notification is intended to achieve the above object." It would follow from the contents of the above notification that for some purposes stated therein the tax payable on the purchase of coir including coir yarn came to be exempted. If not anything else this shows that the coir and the coir yarn are understood as coconuts. In addition to the clear situation appearing from entry Nos. 98 and 49 as discussed hereinabove. 13. There is yet another notification to show continuance of the same understanding even thereafter. This is reinforced by another notification G.O. (P) No. 55/91/TD dated March 30, 1991 (S.R.O. No. 432/91) to indicate the situation that the State Government exempted, inter alia, purchase of coconuts fibre also, with effect from April 1, 1991. The contents of the above notification require reproduction and they are as follows : "Sale or purchase of certain goods - Exemption (Kerala) Notification G.O. (P) No. 55/91/TD dated the 30th March, 1991 S.R.O. No. 432/91. The contents of the above notification require reproduction and they are as follows : "Sale or purchase of certain goods - Exemption (Kerala) Notification G.O. (P) No. 55/91/TD dated the 30th March, 1991 S.R.O. No. 432/91. - In exercise of the powers conferred by section 10 of Kerala General Sales Tax Act, 1963 (Act 15 of 1963) the Government of Kerala, having considered it necessary in the public interest, so to do hereby make an exemption in respect of the tax payable under the said Act (i) on the sale or purchase as the case may be of goods specified in Schedule I below and (ii) the tax payable by the persons or units specified in Schedule II below with regard to their turnover on the sale or purchase as the case may be of goods mentioned against them in the said Schedule subject to such conditions specified therein namely :- Schedule I 1. Coconut fibre This notification shall come into force with effect from the 1st day of April, 1991. Explanatory Note. - (This does not form part of the notification, but is intended to indicate its general purport.) In the budget speech for 1991-1992 it has been announced that coconut fibre and rubberised coir products other than fibre foam will be exempted from sales tax......... This notification is intended to indicate the above objects." It would be seen that this notification was necessary in the public interest. 14. Reading the material on record, in our judgment, these different commodities have been understood by the State Government in its entries as synonymous in the context of inter se relationship. We all know coconut and except what is really known as coconut with kernel, copra and water, the rest of it is commonly understood as coir. The outer portion which is known as husk in the process gets separated and the remaining one is known as coir. This coir to a common examination and appearance and understanding in regard thereto is known as coconut fibre. In the further process this coconut fibre either gets formed into what is commonly understood as coir yarn, also as coir products. In common parlance they are related in the syllogistic relationship of genus and species. This coir to a common examination and appearance and understanding in regard thereto is known as coconut fibre. In the further process this coconut fibre either gets formed into what is commonly understood as coir yarn, also as coir products. In common parlance they are related in the syllogistic relationship of genus and species. If this syllogism is properly understood combined withe the understanding of these items on common parlance theory with reference to the law relating to the exemption, we hold that even the State Government understood these aspects in the same syllogistic pattern of relationship and brought them into one entry to the effect of granting exemption not only to coconut fibre, coir yarn, coir products and bonded fibre, fabrics of coir all in a single situation. This has been the position continuously as would appear from entry Nos. 98 and 49. Even from 1991 onwards coconut fibre also is governed by the same situation of syllogistic relationship. In the context we would like to emphasize that although the first appellate authority has observed that if anybody disagrees with the view that coir will not include coir fibre it is incumbent upon to state that what exactly is meant by coir. It is also necessary to emphasize that throughout the assessee claimed exemption under the State Act. The authorities, as we find from reading the three judgments proceeded on the factual undisputed position that the assessee has earned exemption under the State law - Kerala General Sales Tax Act, 1963. 15. The authorities have proceeded thereafter only to record the conclusion that we cannot say that coconut fibre is the same commodity as coir. 16. We all know what is coir, what is coir fibre and the products that are prepared thereafter. 17. Every word does not receive understanding from the terminology appearing in the text of legislation. With the help of the common dictionary meaning, that too Oxford and Chambers also many times fall short of the requirement of the situation, especially when the article is of day to day use and experience. In our judgment, any attempt to understand the relationship in this manner would compel us to act devoid of our common sense and common knowledge of events that are dearer and nearer to us. We all know what is coconut. We all know what is coir. We all know what is coir fibre. In our judgment, any attempt to understand the relationship in this manner would compel us to act devoid of our common sense and common knowledge of events that are dearer and nearer to us. We all know what is coconut. We all know what is coir. We all know what is coir fibre. Coir fibre is not different from coconut fibre in the context. Coir is the genus in the process of relationship. These are situations of every day use and have therefore to be understood in their popular sense. The apex Court in Ramavatar Budhaiprasad v. Assistant Sales Tax Officer, Akola [1961] 12 STC 286, tells us what popular sense is to be understood. It is that sense which people conversant with the subject-manner with which the statute is dealing would attribute to it. We have shown above that even the State statute has understood all these terms on the relationship of there being cognates of each other, coir being the genus in the situation. How coconut fibre is to be understood in relation to the coconut ? Is this common experience and knowledge and it is on the basis of this the Kerala General Sales Tax Act, 1963 has to be understood and the assessee is exempt thereunder. 18. Therefore the legal consequence under section 8(2A) of the Central Sales Tax Act, 1956 would follow as a necessary sequitor of the situation. 19. All these revision cases are the situation that the conclusions of authorities below are erroneous with regard to a question of law, in regard to applicability of section 8(2A) of the Central Sales Tax Act. The above discussion would show that the petitioner-assessee are entitled to exemption under section 8(2A) of the Central Sales Tax Act, 1956. For all the above reasons in all these revision cases the orders of the three authorities get quashed and set aside. This would result in the dropping of the proceedings under the Central Sales Tax Act, 1956 against the assessee with regard to all these assessment years. Revision cases are allowed. Petitions allowed.