Judgment :- G. SIVARAJAN, J. The matter arises under the Kerala General Sales Tax Act, 1963 (for short, "the Act"). The assessee is the revision petitioner. The assessment years concerned are 1988-89, 1989-90, 1990-91 and 1991-92. 2. The question of law on which notice is issued by order dated March 23, 1999 reads as follows : "Whether, on the facts and in the circumstances of the case, plough (kozhu with handle) is not an item exempt from tax as an agricultural implement worked by hand by virtue of Government Notification S.R.O. No. 342 of 1963 read with S.R.O. No. 1542 of 1987 ?" 3. The assessments of the petitioner for the years 1988-89 to 1990-91 were originally completed allowing exemption on the entire turnover. The same was reopened under section 19 of the Act on the ground that the turnover escaped assessment. The assessing authority noted that the commodity actually dealt with by the appellant is not "kozhu" but plough or kari, which is entirely different from kozhu. He noted that exemption under S.R.O. No. 342 of 1963 as modified by S.R.O. No. 1542 of 1987 is available only to "kozhu". Accordingly he brought the entire sales turnover of plough (kozhu with handle) to tax besides making the petitioner liable on his purchase turnover. Similarly for the assessment year 1991-92 the assessing authority brought the turnover of plough to tax. The appellate authority by a common appellate order held that as per Notifications S.R.O. No. 342 of 1963 and S.R.O. No. 1542 of 1987 "kozhu" is an agricultural implement worked by hand but the commodity actually dealt with by the appellant is plough or kari, which is entirely different from kozhu. He noted that kozhu is only a small metallic part coming under the bottom of plough widely known as plough share. He accordingly rejected the contention of the assessee that the turnover of plough is entitled to be exempted under the said notification. That Sales Tax Appellate Tribunal also by a common order dated October 20, 1998 confirmed the said finding. 4. Learned counsel appearing for the petitioner contended that the petitioner is only a dealer in kozhu which is an agricultural implement worked by hand and therefore entitled to the exemption as provided under S.R.O. No. 342 of 1963 as modified by S.R.O. No. 1542 of 1987. 4. Learned counsel appearing for the petitioner contended that the petitioner is only a dealer in kozhu which is an agricultural implement worked by hand and therefore entitled to the exemption as provided under S.R.O. No. 342 of 1963 as modified by S.R.O. No. 1542 of 1987. He further submitted that even assuming that the commodity dealt with by the petitioner is "kozhu with handle" otherwise known as "plough" still it is entitled to exemption in view of the fact that "plough" is nothing but an agricultural implement used for ploughing the field. He submitted that in fact "plough" is the agricultural implement of which "kozhu" is the main implement and "kozhu" cannot be operated by hand without a handle. He also relied on a decision of the Rajasthan High Court in Assistant Commercial Taxes Officer (Revisions), Ajmer v. Raj. Agro Industries 1987 67 STC 178. Learned Special Government Pleader (Taxes) appearing for the respondent-revenue submitted that exemption under the notifications mentioned above is available only to "kozhu" which is only a part of the agricultural implements, namely, "plough" and that plough is not an item, which is exempted by the said notification. He also submitted that kozhu and plough are different commercial commodities and that exemption notifications have to be strictly construed. In short his submission is that the authorities and the Tribunal have rightly held that the turnover of "plough" dealt with by the petitioner is not entitled to exemption under the notifications mentioned above. 5. In order to appreciate the rival contentions, it is necessary to refer to the two notifications under which exemption is allowed to agricultural implements. S.R.O. No. 342 of 1963 issued under section 10 of the Act, inter alia, granted exemption in respect of the tax payable under the Act on the sale or purchase of goods specified in Schedule I thereto appended and by persons specified in Schedule II thereto appended in regard to their turnover on the sale of goods specified therein subject to the conditions specified therein. Item 8 of the first schedule to the said notification is "agricultural implements worked by hand". Explanation to item No. 8 was added as per S.R.O. No. 1542 of 1987 with effect from November 19, 1987. The agricultural implements which are exempted under item 8 of S.R.O. No. 342 of 1963 are specified therein as follows :"8. Item 8 of the first schedule to the said notification is "agricultural implements worked by hand". Explanation to item No. 8 was added as per S.R.O. No. 1542 of 1987 with effect from November 19, 1987. The agricultural implements which are exempted under item 8 of S.R.O. No. 342 of 1963 are specified therein as follows :"8. Agricultural implements worked by hand : Explanation. - For the purpose of this item the following shall be the agricultural implements worked by hand, namely :- 1. Alavangoos 2. Budding knives 3. Bill hooks 4. Bush knives 5. Cane cutting knives 6. Churku 7. Digging forks 8. Felling knives 9. Grass knives 10. Grubbing mattocks 11. Garden clears 12. Hand forks 13. Malcheles 14. Hand trowds 15. Kodali 16. Kakre (weeding racks) 17. Kunthali 18. Kozhu 19. Mammatties 20. Mammatty forks 21. Pruning knives 22. Potato racks 23. Potato toes 24. Qinthali 25. Rubber tapping knives 26. Sickles 27. Thumba 28. Trenching toes 29. Wading toes 30. Wading forks 31. Manure pan 32. Sledge hammer" Item 18 is "kozhu". Plough (kozhu with handle) is not included. 6. "Kozhu" is a Malayalam word. The word "plough" is defined in the Concise Oxford Dictionary, New 7th edition as implement for cutting furrows in soil and turning it up, consisting of cutting blade and mould-board fixed in frame drawn by tractor, horses, etc., and guided by ploughman. It has also got a meaning "implement or device resembling plough". 7. The question as to whether "sugarcane crushers" is an agricultural implement exempt from sales tax under a notification issued by the U.P. Government was considered by the Supreme Court in D.H. Brothers Pvt. Ltd. v. Commissioner of Sales Tax, U.P. 1992 84 STC 267; AIR 1991 SC 1992. The said notification exempted agricultural implements from the levy of sales tax. Later, fresh notifications were issued from time to time as per which "agricultural implements" worked by human or animal power was specified as including ........................... "sugarcane crusher" was not one of the items specified therein. The High Court in that case considered the question whether "sugarcane crushers" are agricultural implements within the meaning of the words "agricultural implements" as mentioned in the Government notification exempt from U.P. sales tax. "sugarcane crusher" was not one of the items specified therein. The High Court in that case considered the question whether "sugarcane crushers" are agricultural implements within the meaning of the words "agricultural implements" as mentioned in the Government notification exempt from U.P. sales tax. The High Court held that an agricultural implement is an implement that is used in agriculture; any implement that is used after the agricultural process comes to an end and a manufacturing process commences, is not an agricultural implement. The Supreme Court affirmed the view taken by the High Court. While doing so the Supreme Court observed as follows :"While giving meaning to an item in a taxing statute the courts should give it a meaning as intended by the framers of the statute by looking at the various items mentioned in a particular group. The items in one group should be considered in a generic sense. The notification dated November 14, 1980, includes various items under the head 'agricultural implements'. It is no doubt correct that the said definition cannot be confined to the various implements specifically mentioned therein. The definition being inclusive it has a wider import and any other implement which answers the description of an agricultural implement can be included in the definition. A bare reading of the notification, however, shows that all the implements mentioned by name after the word 'including ...........' are by and large those which are used for cultivation of land and other operations which foster the growth and preserve the agricultural produce. None of these implements can be worked after the agricultural process in respect of a crop comes to an end. Therefore, the intention of the framers of the notification could only be to limit the general words in the notification to the implements of the same kind as are specified therein. We are, therefore, of the view that on the plain reading of the notification the sugarcane crushers do not come within the definition of agricultural implements." 8. We have already noted the dictionary meaning of the word "kozhu" as plough-share and "plough" is an implement for cutting furrows in soil and turning it up. Plough consists of a cutting blade and mould board fixed in frame drawn by tractor, horses, etc., and guided by ploughman. We have already noted the dictionary meaning of the word "kozhu" as plough-share and "plough" is an implement for cutting furrows in soil and turning it up. Plough consists of a cutting blade and mould board fixed in frame drawn by tractor, horses, etc., and guided by ploughman. From the dictionary meaning it is seen that the implement plough can be fixed to a tractor for ploughing field; it can be fixed in frame drawn by horses. Similarly it can be worked by hand also. "Kozhu", going by the dictionary meaning is the iron part fixed in plough. "Kozhu", if it fixed in frame drawn by tractor will cease to be an agricultural implement worked by hand. Consequently the exemption under the notification will not be available. "Kozhu", if a handle is fixed to it, can be worked by hand and used for ploughing the field and would get the exemption under the notification. 9. Now the question to be considered as already mentioned in the opening paragraph of this judgment is as to whether plough ("kozhu" with handle) is an item exempt from tax as an agricultural implement worked by hand under the notifications mentioned above. The dictionary meaning of the word "kozhu" as already noted is a metallic part fixed at the bottom of plough known as plough share. Plough and plough share may be two different commercial commodities. The contention of the Government Pleader is that plough is not an item of agricultural implement specified in the notification and therefore the turnover of plough dealt with by the petitioner is not liable to be exempted. It must be noted that the only use of "kozhu" is for ploughing the field. "Kozhu", in order to be operated as agricultural implement by hand should have a handle. Without a handle it is not practicable to operate it by hand. If the stand of the Revenue based on the dictionary meaning of the word "kozhu" that it is only a part of the agricultural implement "plough" is accepted "kozhu" will cease to be an agricultural implement as generally understood. It is in the above circumstances it has become necessary to understand what the framers of the notification intended by using the word "kozhu" as an agricultural implement worked by hand. 10. It is in the above circumstances it has become necessary to understand what the framers of the notification intended by using the word "kozhu" as an agricultural implement worked by hand. 10. The question therefore would be to find out, as held by the Supreme Court in D.H. Brothers Pvt. Ltd. v. Commissioner of Sales Tax, U.P. 1992 84 STC 267; AIR 1991 SC 1992, the meaning of the word "kozhu" as intended by the framers of the notification and this has to be gathered by looking at the various items mentioned as agricultural implements worked by hand in the notification itself. We have already extracted the 32 items specified under item 8 of the notification. It can be seen that all the items excepting item "kozhu" are agricultural implements by themselves. None of them are parts of the agricultural implements. Each one of them is an agricultural implement which can be worked by hand without anything being added to it. "Kozhu" is also included in the said group. This would clearly indicate that the framers of the notification had used the word "kozhu" only to mean the implement for ploughing the field, viz., plough or kozhu with handle. Any other meaning to be given to the word "kozhu" will defeat the purpose of the exemption granted to the agricultural implement "kozhu". This is also consistent with the object, viz., the exemption is only to agricultural implement worked by hand. "Kozhu with handle" can be worked only by hand whereas "kozhu" can be fixed to tractor in which case it fall outside the exemption since operated by other devices. 11. Though exemption notifications have to be construed strictly a construction which would advance the purpose is justified. A reasonable construction of the word "kozhu" used in item 8 of the notification S.R.O. No. 342 of 1963 as modified by S.R.O. No. 1542 of 1987 keeping in mind the purpose of its inclusion can only mean plough (kozhu with handle). We accordingly hold that plough (kozhu with handle) is an item of agricultural implement exempt from tax under S.R.O. No. 342 of 1963 as modified by S.R.O. No. 1542 of 1987. The question of law posed in the opening para of this judgment is answered in the negative against the Revenue and in favour of the assessee. 12. We accordingly hold that plough (kozhu with handle) is an item of agricultural implement exempt from tax under S.R.O. No. 342 of 1963 as modified by S.R.O. No. 1542 of 1987. The question of law posed in the opening para of this judgment is answered in the negative against the Revenue and in favour of the assessee. 12. In the light of the above, we set aside the orders of the assessing authority, the Appellate Assistant Commissioner and the Sales Tax Appellate Tribunal for all the four assessment years as illegal, erroneous and unsustainable. The assessing authority is directed to complete the assessment for the four years exempting the turnover of plough (kozhu with handle) from tax under S.R.O. No. 342 of 1963 as modified by S.R.O. No. 1542 of 1987. These tax revision cases are allowed as above. Order on C.M.P. No. 1494 of 1999 in T.R.C. No. 53 of 1999 dismissed. Order on C.M.P. No. 1500 of 1999 in T.R.C. No. 54 of 1999 dismissed. Order on C.M.P. No. 1502 of 1999 in T.R.C. No. 55 of 1999 dismissed. Order on C.M.P. No. 1504 of 1999 in T.R.C. No. 56 of 1999 dismissed. Petitions allowed.