ORDER A.M. Sapre, J. 1. By this petition, preferred under twin articles 226 and 227 of the Constitution of India, the petitioner seeks quashing of assessment order dated December 19, 1988 (annexure B) and revisional order dated March 7, 1990 (annexure C) passed under the "Madhya Pradesh General Sales Tax Act, 1958" (since repealed). The question that falls for consideration in this petition is whether elastic tapes are exempted from payment of sales tax? The facts necessary for the disposal of the writ lie in the narrow compass. They need mention infra. 2. The petitioner-firm was engaged in manufacture of various types of laces and tapes at the relevant time. They got themselves registered as dealer under the provisions of the M.P. General Sales Tax Act, 1958 (for brevity, "the Act") for the aforesaid product and also some other as is clear from the certificate of registration (annexure R/2). 3. In exercise of the powers conferred by Section 12 of the Act, the State Government issued Notification No. F.A-3(21)-1985(24)-ST-V, dated April 11, 1985, whereby various commodities/goods specified in the Schedule appended to the notification were exempted from payment of sales tax. So far as this petition is concerned, the goods specified in entry 25(iv) of Schedule are relevant. The entry reads as under : S.No Class of goods Extent of Restrictions and conditions exemption subject to which exemption is granted 25 (iv) Tapes, niwars and laces 4. For the period November 13, 1985 to November 1, 1986, the petitioner filed their sales tax return under the Act and claimed exemption from payment of sales tax on the sale of elastic tapes. According to them, elastic tapes manufactured and sold fall within the aforesaid mentioned exempted entry and hence were not exigible to tax. 5. By order dated December 19, 1988, passed by the learned assessing authority, the contention of the petitioner was not accepted. In the opinion of assessing officer, what was exempted under the exempted entry was tapes and riot elastic tapes manufactured and sold by the petitioner. The learned assessing officer, therefore, proceeded to hold the elastic tapes to be exigible to tax and assessed it by determining the tax payable on its sale. The petitioner, felt aggrieved by the aforesaid assessment order, preferred the revision to the Additional Commissioner of Sales Tax being Revision No. (S) 89/42. The learned assessing officer, therefore, proceeded to hold the elastic tapes to be exigible to tax and assessed it by determining the tax payable on its sale. The petitioner, felt aggrieved by the aforesaid assessment order, preferred the revision to the Additional Commissioner of Sales Tax being Revision No. (S) 89/42. The learned Additional Commissioner, by its order dated March 7, 1990 (annexure C) dismissed the revision and upheld the order of assessing authority. The learned Additional Commissioner also concurred with the opinion of assessing authority and held that what was exempted was only tapes and not elastic tapes. He also held that since the petitioner was engaged in manufacture and sale of elastic tapes as seems apparent on the basis of inspection report of the inspector concerned, and hence not entitled for exemption under the exempted entry. It is against these orders, the petitioner felt aggrieved and approached to this Court questioning legality and propriety of the aforesaid two orders which are impugned in this writ petition. 6. The State has filed return and has supported the orders impugned passed by the authorities. 7. I have heard Shri Pravin Pal, counsel for the petitioner and Shri S. Mukati, learned Government Advocate, for the respondents. 8. The submission of Shri Pal, learned counsel for the petitioner, was that both the authorities committed serious error of law by interpreting the exemption entry. According to learned counsel, a plain reading of exemption entry would manifestly suggest that all kinds of tapes are exempted from payment of tax, be it made of elastic, or cotton or any other raw material. He further submitted that what is exempted from payment of sales tax is "tapes" and the moment it is proved that the commodity in question is identified as "tapes", it is exempted from tax under the aforementioned entry. Learned counsel pointed out that when the authority found as a fact that petitioner had manufactured and sold elastic tapes during the relevant period, exemption should have been allowed on the said tapes under the entry 25(iv) ibid. 9. In reply, learned Deputy Government Advocate for the State, while supporting the order passed by the authority below, urged that the words "elastic tapes" not being in the exempted entry, i.e., entry 25(iv), the petitioner is not entitled to claim any benefit. 9. In reply, learned Deputy Government Advocate for the State, while supporting the order passed by the authority below, urged that the words "elastic tapes" not being in the exempted entry, i.e., entry 25(iv), the petitioner is not entitled to claim any benefit. According to him, the report of Inspector who made the inspection of the petitioner-factory also shows that petitioner is using elastic in tapes and hence, according to him, no benefit can be taken to claim exemption under entry 25(iv). It was his submission that if the intention of Legislature was to extend benefit to elastic tapes also then in that event, there would have been specific entry to that effect in the notification. He, therefore, prayed for the dismissal of the writ petition and for upholding the orders impugned in the writ. 10. Before embarking upon the merits of the controversy, it may be useful to keep in mind certain well-settled principles while interpreting taxing notification and in particular notification granting exemption. It is ruled that whenever the words granting exemption fall for interpretation, they must be construed not in any technical sense nor from the botanical point of view but they (words) have to be understood in their common parlance. It is also explained that while construing their popular meaning, sense which people conversant with subject-matter with which the statute is dealing would attribute to them would apply (see : Ramavatar Budhai-prasad v. Assistant Sales Tax Officer, Akola [1961] 12 STC 286 (SO and Viswa & Co. v. State of Gujarat [1966] 17 STC 581 (Guj). 11. Perusal of entry 25(iv) quoted (supra) indicates that what is made exempted from payment of sales tax is tapes, niwars and laces. In my opinion, the use of expression "tapes" is so widely worded that it would include within itself tapes made of elastic also. In other words, to my mind, the intention of Legislature is to extend exemption to all kinds of tapes. The emphasis is not to a tape made by use of particular raw material but it is on ultimate products namely "tapes" sold in the market by and under the name "tapes". It is a common knowledge in market that in modern days such tapes are made of several inputs which may include elastic, cotton or any synthetic fibre. The emphasis is not to a tape made by use of particular raw material but it is on ultimate products namely "tapes" sold in the market by and under the name "tapes". It is a common knowledge in market that in modern days such tapes are made of several inputs which may include elastic, cotton or any synthetic fibre. Perusal of three expressions specified in entry clearly suggests that benefit is not confined to specific class of tape made of particular raw material. Had it been so, it would have been so specified. I am fortified by the apt observations of their Lordships of the Madras High Court in a case reported in Sapt Textile Products (India) Private Ltd. v. State of Madras [1965] 16 STC 267. While dealing with the sales tax matter to find out the distinction between the two words "cotton" and "cotton waste", their Lordships of the Madras High Court had an occasion to observe : "The sales tax assessment being intended primarily for assessment of dealers engaged in the trade, one cannot dissociate the meaning which a particular commodity has acquired in the market, for the purpose of identifying the commodity for levy of sales tax. The proper rule in such cases will be to give to the commodity the particular meaning, which the buyer and the seller in the market usually give to it, unless the statute has taken care to prescribe any special marks of description or identification." 12. In somewhat similar circumstances, a question arose before the Allahabad High Court in a case reported in Commissioner of Sales Tax v. Ashok Elastic Works [1971] 28 STC 743 as to whether dori and fita are kinds of lace and tape or/and in any event, whether they fall within the entry "cotton fabrics of all varieties" so to enjoy the exemption from payment of sales tax under the U.P. Sales Tax Laws ? In this case also, elastic was used as raw material in manufacturing dori and fita. Their Lordships after discussing various dictionary meanings and popular sense of these products, came to a conclusion that dori and fita to be of kind of lace and tapes. It was also held that they also fall in the entry "cotton fabrics". In this case also, elastic was used as raw material in manufacturing dori and fita. Their Lordships after discussing various dictionary meanings and popular sense of these products, came to a conclusion that dori and fita to be of kind of lace and tapes. It was also held that they also fall in the entry "cotton fabrics". This is what their Lordships held while answering the reference in favour of dealer : "The addition of elastic material, the nature of which has not been specified in the statement of the case, will not alter its nature. By the addition of the elastic material, the product can be called as elastic cotton fabric, but it remains a cotton fabric nevertheless. As stated above, we answer the question by saying that dori and fita are a kind of lace and tape, and, in any case, they fall within the entry "cotton fabrics of all varieties", and, as such, are covered by the Notification No. S.T. 4064/X-960(4)-58 dated 25th November, 1958, and, are therefore, exempt from tax." 13. I am in respectful agreement with the aforesaid reasoning of Allahabad High Court and hold "that the expression 'tapes' specified in entry 25(iv) would include elastic tapes and is, accordingly exempt from payment of sales tax by virtue of the said notification for the period mentioned therein." 14. The petition is, accordingly, allowed. The impugned order of assessment dated December 19, 1988 (annexure B) and revisional order dated March 7, 1990 (annexure C) in so far as they hold that elastic tapes are not entitled for exemption under aforesaid notification referred (supra) are quashed. The security amount, if deposited, may be refunded to the petitioner as per the rules. No costs.