S. ANANDA REDDY, J. ( 1 ) THIS writ petition is filed praying for the issue of writ of certiorari or any other appropriate writ or order and quash the revised assessment proceedings in g. I. NO. 6791/94-95, dated 10-12-1996 after calling for the records relating to the said revised proceedings. ( 2 ) IT is stated that the petitioner was carrying on business in silver as a registered dealer on the rolls of the respondents. Bullion and Specie are taxable at the rate of 2% with effect from 8-7-1983 under item 20 of the first Schedule of Andhra Pradesh general Sales Tax Act, 1957 (hereinafter referred to as the APGST Act ). Same rate is also applicable under item 21, with reference to the articles and jewellery made of bullion and/or specie or both, excluding precious stones. It is also stated that explanation-1 to the said Schedule defines bullion as pure gold or silver and includes gold or silver mixed with copper, led or any other kind of base metal. While so, the government of Andhra Pradesh issued g. O. Ms. No. 1092 dated 31st October 1994 under Section 9 (1) of the APGST Act reducing the net rate of Sales-tax to 1/2 per cent on sale of bullion and specie (Gold ). The APGST Act was amended by Act 22 of 1995 with effect from 1st April 1995 prescribing the Sales-tax in the case of bullion and specie at the rate of 4%. Again the Government issued a Notification under section 9 (1) of the APGST Act in g. O. Ms. No. 252, dated 19th May, 1995 reducing the rate of Sales-tax in the case of bullion and specie (Gold) to 1/2 per cent with effect from 1-4-1995. ( 3 ) FOR the assessment year 1994-95, the petitioner returned a turnover in silver bars in a sum of Rs. 14,33,01,470 and paid Sales-tax at the rate of 1/2 % and the assessing authority accepted the said returns and completed the assessment on 27-11-1995. Later, the Assessing Officer issued notice dated 17-08-1996 proposing to reopen the assessment under Section 14 (4) (c) of the apgst Act and bringing the above turnover to tax at 2%, apart from additional tax and surcharge, on the premise that g. O. Ms. No. 1092 and G. O. Ms. . Later, the Assessing Officer issued notice dated 17-08-1996 proposing to reopen the assessment under Section 14 (4) (c) of the apgst Act and bringing the above turnover to tax at 2%, apart from additional tax and surcharge, on the premise that g. O. Ms. No. 1092 and G. O. Ms. . No. 252 reducing the rate of Sales-tax to 1/2 per cent is applicable only to Gold bullion and specie but not silver bullion. Questioning the said show-cause notice, the petitioner filed W. P. No. 21503 of 1996 and this Court disposed of the said writ petition observing that it would be open to the petitioner to file objections before the Respondent-authorities it is further stated that thereafter the petitioner filed objections before the Respondent claiming that the reduced rate of Sales-tax is applicable not only to gold bullion but also to silver bullion and the bracketed word gold used in the above G. Os. applies only to specie and not to bullion. Thereafter the Assessing officer rejected the said objections of the assessee and framed reassessment. Questioning the said reassessment, the petitioner has come up before this Court in the present writ petition. ( 4 ) THE learned Counsel for the petitioner contended that though a remedy of appeal is available to the petitioner dealer, this said remedy of appeal to the Appellate Deputy commissioner is not effective in the light of the clarification given by the Commissioner of Commercial Taxes by his proceedings dated 22-03-1995, clarifying that the g. O. Ms. No. 1092 is applicable only to the gold bullion and not to silver bullion. Hence, the present writ petition. The learned Counsel also contended that the issue relates only to the interpretation to the g. O. , therefore to have an effective and binding decision the petitioner has approached this Court. The learned counsel also contended that a perusal of the g. O. clearly shows that the bracketed word gold was inserted only after specie and not either before or after bullion . Therefore, the said bracketed word gold is relevant for the word specie but not for the word bullion . If the G. O. , is so interpreted, the reduced Sales-tax is available to the petitioner/dealer at half per cent as provided therein, which was accepted by the Assessing Officer at the first instance. Therefore, the said bracketed word gold is relevant for the word specie but not for the word bullion . If the G. O. , is so interpreted, the reduced Sales-tax is available to the petitioner/dealer at half per cent as provided therein, which was accepted by the Assessing Officer at the first instance. Therefore, there is no case for the Assessing officer to change his opinion to revise the assessment levying the Sales-tax at higher rate. The learned Counsel also contended that the Government itself has clarified by issuing subsequent Notification in g. O. Ms. No. 625, dated 31-07-1996 by omitting the expression gold which was inserted in G. O. Ms. Nos. 1092 and 252 in the bracket immediately after the term specie . It is therefore contended that when once the government has also clarified that it is not intended to give the benefit of lower rate of tax not only to gold but also to silver bullion, the action of the respondent authorities in reopening the assessment as well as framing the reassessment is not in accordance with law and it is only a change of opinion with reference to the same notification issued by the Government under Sec. 9 (1) of the APGST Act. The learned Counsel also contended that if mere is any ambiguity in the interpretation of the provision or the G. O. , under which benefit was granted to the dealers, it should be interpreted in favour of the assessee and if so interpreted there is no case for the department to levy higher rate of tax in the revised assessment. The learned Counsel for the petitioner relied upon the judgment of the Apex Court in the case of C. S. T. vs. Indstrial Coal Enterprises1 and contended that where there is a provision for concession it should be construed liberally arid if so construed the petitioner is entitled for the benefit of reduced rate of tax. ( 5 ) A counter has been filed on behalf of the respondents, though not in the same writ petition, but in the other connected writ petition dealing with the same issue. It is the contention of the respondents that the reduced rate of Sales-tax as per the G. Os. ( 5 ) A counter has been filed on behalf of the respondents, though not in the same writ petition, but in the other connected writ petition dealing with the same issue. It is the contention of the respondents that the reduced rate of Sales-tax as per the G. Os. issued by the Government under Sec. 9 (1) of the APGST Act is applicable to both bullion and specie, but it is only with reference to gold bullion and specie. As such the expression was specifically inserted in the bracket immediately after the above terms bullion and specie. ( 6 ) THE learned Government Pleader has contended that there is no justification to contend that the term gold is applicable only to specie and not to bullion. Both the expressions are mentioned under Item 20 of the First Schedule. Therefore, it is contended that the interpretation sought to be given by the petitioner to the above G. O. , is not proper and correct. The learned counsel also stated that the Dealers association have sought for clarification from the Commissioner of Commercial taxes, in the light of the G. Os. , issued by the Government and it was clarified by the commissioner by his letter dated 22-3-1995, that the reduced rate of tax is applicable only to the gold bullion and specie and not to silver bullion and specie. The learned counsel also contended that the legislative intention is very clear from the words used in the G. O. , and there is absolutely no ambiguity to give any other interpretation than what is clear from the reading of the said G. O. Therefore, it is contended that there is no ambiguity. The learned Counsel also relied upon the judgment of the supreme Court in the case of W. T. Commissioner, Bihar vs. Kripashankar2 and contended that the taxing provision must receive a strict construction at the hands of the Courts and if such strict construction is given, the petitioner is not entitled to any benefit. ( 7 ) FROM the above rival contentions the issue that arises for consideration is whether the reduced rate of Sales-tax at half per cent instead of 2 per cent, is available in terms of the G. O. Ms. No. 1092, dated 31-10-1994 and G. O. Ms. No. 252, dated 19-5-1995 to silver bullion? ( 7 ) FROM the above rival contentions the issue that arises for consideration is whether the reduced rate of Sales-tax at half per cent instead of 2 per cent, is available in terms of the G. O. Ms. No. 1092, dated 31-10-1994 and G. O. Ms. No. 252, dated 19-5-1995 to silver bullion? ( 8 ) IT is not in dispute that the petitioner is a dealer in silver bullion. Under item-20 of the First Schedule to the APGST Act the original rate prescribed is at 2 per cent. However, the State Government issued notification under Sec. 9 (1) of the APGST act in G. O. MS. NO. 1092 dated 31-10-1994 reducing the rate of Sales-tax to half per cent in respect of bullion and specie (gold) from the date of the said Notification. The said entry is as under: FIRST SCHEDULE S. No. Description of Goods Point of levy Rate of tax Effective from 20 Bullion and specie. (1020) At the point of first sale in the State, 2 4 8-7-1983. 1-4-1995 ( 9 ) FOR convenience, the relevant portions of the above two G. Os,, are extracted hereunder: g. O. Ms. No. 1092 Rgv. . (Ctii) Dept. . dt. 31-10-1994: notification-1 in exercise of the powers conferred by the sub-sec. (1) of Sec. 9 of the Andhra pradesh General Sales Tax Act, 1957 (Act-VI of 1957), the Governor of andhra Pradesh hereby directs: (a) that the tax leviable under the said act on the said Act on the sale of bullion and specie (gold) be reduced from 2% to 1/2% all included (net V1/2% ). (b) that the tax leviable under the said act on the sale of jewellery, including those set with precious stones be reduced to 2%. (c) that the tax leviable under the said act on the sale of precious stones loose, other than pearls, be reduced to 2%. This notification shall come into force with immediate effect. (b) that the tax leviable under the said act on the sale of jewellery, including those set with precious stones be reduced to 2%. (c) that the tax leviable under the said act on the sale of precious stones loose, other than pearls, be reduced to 2%. This notification shall come into force with immediate effect. NOTIFICATION-II"in exercise of the powers conferred by the sub-section (1) of Section 9 of the Andhra Pradesh General Sales Tax act, 1957 (Act VI of 1957), the governor of Andhra Pradesh hereby directs that where a tax has been paid on the purchase of gold inside the state, the tax leviable under the said act, on the sales of jewellery manufactured out of such tax paid gold and sold in the State, shall be reduced by the amount of tax so paid on such gold. This notification shall come into force with immediate effect". ( 10 ) THE above G. O. , was superseded by notification No. XXXIV in G. O. Ms. No. 252, revenue, dated 19-5-1995 (w. e. f. 1-4-1995 ). The said notification reads as under: notification- XXXIV"in exercise of the powers conferred by sub-section (1) of Section 9 of the andhra Pradesh General Sales Tax act, 1957 (Act VI of 1957) and in suppression of the Notifications I and ii issued in G. O. Ms. No. 1092, revenue, dated 31-10-1994 the governor of Andhra Pradesh hereby directs. (a) that the tax leviable tinder the said act shall be in respect of sale of bullion and specie (gold) be at the reduced rate of 1/2% (0. 5 ). (b) that the tax leviable under the said act shall in respect of sale of jewellery, including those set with precious stones be at the reduced rate of 2%. (c) That the tax leviable under the said act shall in respect of sale of precious stones loose, other than pearls, be at the reduced rate of 2%. It shall be deemed to have come into force with effect from the 1st April. 1995. " ( 11 ) THE assessee filed its return and paid the tax at the rate of half per cent in respect of the turnover of silver bars. The said return was accepted and assessment was framed on 27-11-1995. It shall be deemed to have come into force with effect from the 1st April. 1995. " ( 11 ) THE assessee filed its return and paid the tax at the rate of half per cent in respect of the turnover of silver bars. The said return was accepted and assessment was framed on 27-11-1995. But, however, the assessing Officer later issued notice under section 14 (4) (c) of the APGST Act on 17-08-1996 proposing to reopen the assessment and called for objections from the assessee. Though objections were filed by the assessee opposing the said reopening of the assessment, they were rejected and re-assessment was framed on 10-12-1996 bringing the turnover to tax at the rate of 2%. The contention of the assessee is that the benefit of reduced rate of tax is available to both gold and silver bullion and the restriction contained by the expression gold in the bracketed portion is applicable only to the specie and not the bullion. ( 12 ) TO appreciate the contention of the petitioner, it is better to look into the meaning of the expressions bullion and specie mentioned under item No. 20 of the first Schedule to the APGST Act. These expressions are not defined in the Act, but explanation No. 1 under the First Schedule, provides the meaning of the expression "bullion" which is as under explanation-I: The expression bullion in items 20 and 21 means pure gold or silver and includes gold or silver mixed with copper, lead or any other kind of base metal. From the above it is clear that bullion means pure gold or silver and includes gold or silver mixed with any other kind of base metal. As far as specie is concerned, it is not even explained in the Act. Therefore, we have to consider the ordinary meaning of the expressions as contained in the dictionaries. As per "the New international Webster s comprehensive Dictionary" the meaning of the bullion and specie is follows: bullion: Gold or silver uncoined or in mass, as in bars, plates, or the like. Specie: Coined money; coin synonyms under money. Species: A metal image considered as having the likeness of some object in nature. As per "black s Law Dictionary". Bullion: Gold and silver intended to be coined. Specie: Coined money; coin synonyms under money. Species: A metal image considered as having the likeness of some object in nature. As per "black s Law Dictionary". Bullion: Gold and silver intended to be coined. "bullion" encompasses, at the very least, any solid mass of uncoined gold or silver whatever its shape so long as its shape does not enhance its value. Specie: Coin of the precious metals, of a certain weight and fineness, and bearing the stamp of the Government, denoting its value as currency, metallic money; eg. Gold or silver coins. As per "the concise Oxford Dictionary (1990 Edition): bullion: a metal (esp. gold or silver) in bulk before coining, or valued by weight specie: coin money as opposed to paper money. As per "the Law Lexicon (the encyclopedia Law Dictionary)" by p. Ramanatha Aiyar: bullion: Uncoined gold or silver; gold or silver in the mass; gold or silver smelted and not perfectly refined, or refined but in bars; ingots or any uncoined form, as plate; often used to denote gold and silver, both coined or uncoined, when reckoned by weight or in the mass, especially used of foreign or uncurrent coin. Bullion and specie: Bullion means gold or silver in the mas. Ornaments and other articles of gold cannot be regarded as bullion because even if gold and anti-quated, they are not raw or un wrought gold or gold in the mass. The word specie means any metallic coin which is used as currency. Specie: Metallic money issued by public authority. ( 13 ) THE Apex Court in the case of Deputy commissioner of Sales Tax vs. M/s. G. S. Pai and Co. 3 considered these two terms bullion and specie", may be under a different context i. e. , whether ornaments and other articles of gold could be regarded as bullion and specie as specified in Entry 56 of the first Schedule of the Kerala General Sales tax Act, 1963. The Apex Court considered the same as under: "we will first consider the question whether the ornaments and other articles of gold purchased by the assessee fall within the description of "bullion and Specie" given in entry 56. There are two expressions in this Entry which require consideration; one is "bullion" and the other is "specie". The Apex Court considered the same as under: "we will first consider the question whether the ornaments and other articles of gold purchased by the assessee fall within the description of "bullion and Specie" given in entry 56. There are two expressions in this Entry which require consideration; one is "bullion" and the other is "specie". Now there is one cardinal rule of interpretation which has always to be borne in mind while interpreting entries in Sales-tax legislation and it is that the words used in the entries must be construed not in any technical sense nor from the scientific point of view but as understood in common parlance. We must give the words used by the legislature their popular sense meaning "that sense which people conversant with the subject-matter with which the statute is dealing would attribute to it". The word "bullion" must, therefore, be interpreted according to ordinary parlance and must be given a meaning which people conversant with this commodity would ascribe to it. Now it is obvious that "bullion" in the popular sense cannot include ornaments or other articles of gold. "bullion" according its plain ordinary meaning means gold or silver in the mass. It connotes gold or silver regarded as raw material and it may be either in the form of raw gold or silver or ingots or bars of gold or silver. . . . the word "specie" has a recognized meaning and according to webster s New World Dictionary, it mearts "coin, as distinguished from paper money". The Law Dictionaries also give the same meaning. . . . . . Therefore, according to common parlance, the word "specie" means any metallic coin which is used as currency and if that be the true meaning, it is obvious that ornaments and other articles of gold cannot be described as "specie". ( 14 ) FROM the above, it is clear that bullion means gold or silver in mass, in bars, plates etc. , in uncoined form; whereas specie means coined gold or silver or any other metal and also used as currency. Therefore, it is clear that the distinction between the two expressions is only that the former refers to gold and silver when it is in bulk form, either unshaped or shaped like bars, plates etc. , whereas later refers to the coined form of silver or gold. Therefore, it is clear that the distinction between the two expressions is only that the former refers to gold and silver when it is in bulk form, either unshaped or shaped like bars, plates etc. , whereas later refers to the coined form of silver or gold. The contention of the petitioner is that the bracketed word "gold" is used after the expression specie , therefore, it applies only to that expression but not to bullion therefore, both gold and silver bullion is entitled to the concessional rate of Sales-tax as contained in the G. Os. in question. According to the learned Counsel for the petitioner, if the Legislature intends to restrict the benefit only to gold bullion, then such word would have find place either before or after the expression bullion . The absence of it makes clear that the restriction is only to specie and not to bullion . We are unable to accept the said contention of the learned Counsel for the petitioner. The expressions "bullion and specie" are used under one item which shows that there is no much distinction between the two; both the expressions include gold and silver. If the legislative intention is to confirm concessional rates of tax not only in respect of gold bullion and specie but also silver bullion, it would have made clear. On the other hand, when the Legislature had used the term gold after the expressions bullion and specie it clearly shows the legislative intention that concessional rates are applicable only to gold bullion and specie. It was contended by the learned Counsel for the petitioner that the bracketed word gold contained in clause (a) of the two g. Os. issued prescribing reduced rate of sales-tax was omitted by issuing g. O. Ms. No. 625, dated 31-7-1996 with effect from 1-8-1996, which clearly shows that the intention of the Legislature was that the concessional rate of tax is to be applied to both gold and silver bullion and specie. We do not find any merit in the said contention of the learned Counsel. It is not the case that the bracketed word "gold" in clause (a) after the expression bullion and specie was omitted from the date of the original G. Os. , when concessional rates of tax was introduced. We do not find any merit in the said contention of the learned Counsel. It is not the case that the bracketed word "gold" in clause (a) after the expression bullion and specie was omitted from the date of the original G. Os. , when concessional rates of tax was introduced. If for any reasons, the concessional rate of tax is extended for other items later that do not confer any benfit for the earlier period unless it is specifically extended in the order itself. Therefore, there is no merit in the above contention. It is held by the Apex Court that the object of the relevant exemption notification and the intention of the State government in granting exemption are to be taken into account while interpreting the words used in the G. O. s. , in question. Here there is no ambiguity in the expressions used in the G. O. Further, the intention of the State Government is also clear that only gold bullion and specie is entitled for concessional rate of tax. ( 15 ) FURTHER, it is clear from the records that immediately after issuing the g. O. Ms. No. 1092, the Jeweller s Association sought for a clarification from the commissioner of Commercial Taxes and accordingly he has also issued a clarification on 22-3-1995 clarifying that the concessional rates of tax is applicable only to gold bullion, specie and Jewellery. Therefore, the petitioner is aware of the liability to tax at the normal rate in respect of silver bullion. ( 16 ) HENCE, there is no merit in the writ petition and the same is accordingly dismissed. No costs.