JUDGMENT OM PRAKASH, C.J. – This revision filed by the assessee, raises a short question for consideration whether under the Explanation to entry 51 of the First Schedule appended to the Kerala General Sales Tax Act, 1963 the assessee would be entitled to the reduction of tax leviable on coconut oil from the tax levied on the purchase turnover of copra or coconut, from which the coconut oil was produced. 2. The Appellate Tribunal took the view that under the Explanation, reduction will be available only when tax is leviable on coconut oil as well as on coconut oil cake, produced from the copra or coconut, purchased by the assessee and that if the tax is leviable on either of the two, then reduction will not be available. For the assessment year 1990-91, which is relevant herein, tax was not leviable on coconut oil cake, as that was exempt. The Tribunal, therefore, held that reduction could not be claimed. 3. This question came up for consideration before this Court in Muttam Oil and Flour Mills v. State of Kerala [1998] 109 STC 182; 1997 KLJ (TC) 114 and then this Court held as under : "........ In our judgment the language is more than clear and it is not necessary as has been held by the Tribunal that both coconut oil and coconut oil cake should be subjected to levy of tax before considering the claim of reduction in regard thereto. Such a consideration is not possible in view of the situation that tax collected by the assessee with regard to coconut oil cake is forfeited to the Government. If it is forfeited to the Government, the situation will have to be understood for the purpose of consideration of benefit of explanation not in the manner in which the Tribunal has observed but it will have to be taken into consideration that the tax on the coconut oil would be no less relevant for reduction in the context, simply by virtue of the position that during the year in question tax on coconut oil cake is in the exempted category leading to the situation of forfeiture of amount to the Government with regard to the tax collected by the assessee in regard thereto." 4. Observing as above, this Court in Muttam Oil and Flour Mills v. State of Kerala [1998] 109 STC 182; 1997 KLJ (TC) 114 extended the benefit of the Explanation to the assessee, though, in that case also, coconut oil cake was not chargeable to tax. 5. Following the dictum of this Court in Muttam Oil and Flour Mills v. State of Kerala [1998] 109 STC 182; 1997 KLJ (TC) 114 it must be held that the assessee would be entitled to reduction of tax leviable on the turnover of coconut oil by the amount of tax levied on the purchase turnover of copra or coconut, from which the coconut oil was produced. Explanation to entry 51 was, introduced to avoid double taxation. The rationale underlying the Explanation is that when coconut oil and coconut oil cake are produced from the raw material, viz., copra or coconut, then tax leviable on the finished product, that is, coconut oil and coconut oil cake, will be reduced by the amount of tax levied on the purchase turnover of the raw material. From copra or coconut, coconut oil and coconut oil cake both are produced together. Coconut oil cake is a by-product of coconut oil and, therefore, the conjunction "and" has been used between the words "coconut oil .... coconut oil cake" in the Explanation. From the use of conjunction "and" between the words "coconut oil ..... coconut oil cake", no inference can be drawn that unless both products are chargeable to tax, reduction will not be available for the amount of tax levied on the purchases of raw material. Coconut oil and coconut oil cake both are simultaneously produced and, therefore, from the angle of drafting, the use of conjunction "and" is necessary. The Explanation does not indicate that if coconut oil cake a by-product is not chargeable to tax, then tax leviable on coconut oil will not be reduced by the amount of tax levied on the copra or coconut, from which the coconut oil was produced. We are, therefore, of the view that the Appellate Tribunal misinterpreted the clear language, employed in the Explanation. The assessee will, therefore, be entitled to the reduction of tax leviable on coconut oil by the amount of tax levied on the purchase of the raw material, from which coconut oil was produced. 6. In the result, the revision succeeds and is allowed. The assessee will, therefore, be entitled to the reduction of tax leviable on coconut oil by the amount of tax levied on the purchase of the raw material, from which coconut oil was produced. 6. In the result, the revision succeeds and is allowed. The impugned order of the Appellate Tribunal to this extent is set aside. Petition allowed.