JUDGMENT RAJES KUMAR, J. - Present two revisions under section 11 of the U.P. Trade Tax Act, 1948 (hereinafter referred to as "the Act") are directed against the order of the Tribunal dated April 7, 2000 relating to the assessment years 1994-95 and 1995-96. The dealer - opposite party (hereinafter referred to as "the dealer") was carrying on the business of manufacture and sales of cattle feed which consists of 90 per cent molasses, two per cent urea, one per cent sewar, five per cent ordinary salt and two per cent black salt. In the returns filed by the dealer, exemption on the turnover of cattle feed was claimed up to September, 1994 and thereafter on the turnover of such cattle feed, five per cent tax was admitted and paid. However, during the course of the assessment proceeding, dealer disputed the taxability on the cattle feed even for the period after October 1, 1994. The claim of the dealer was that after October 1, 1994, "balanced cattle feed" was made taxable under the Notification No. TT-2-3403/X-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994, while the cattle feed manufactured and sold by it was not balanced cattle feed. Submission of the dealer was that the cattle feed sold by the dealer did not contain any vitamin and was provided to cattle, to make the ordinary food tasty. The assessing authority has not accepted the plea of the dealer and levied the tax on such cattle feed on the turnover after October 1, 1994 under the aforesaid Notification No. TT-2-3403/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 at the rate of five per cent treating it as balanced cattle feed. Being aggrieved by the order of the assessing authority, dealer filed appeals before the Deputy Commissioner (Appeals), Trade Tax, Gorakhpur. The Deputy Commissioner (Appeals), Trade Tax, Gorakhpur vide order dated January 20, 1999, dismissed both the appeals. Being aggrieved by the order, dealer further filed second appeals before the Tribunal. The Tribunal by the impugned order allowed the appeals and granted exemption on the turnover of such cattle feed even after October 1, 1994. The Deputy Commissioner (Appeals), Trade Tax, Gorakhpur vide order dated January 20, 1999, dismissed both the appeals. Being aggrieved by the order, dealer further filed second appeals before the Tribunal. The Tribunal by the impugned order allowed the appeals and granted exemption on the turnover of such cattle feed even after October 1, 1994. The Tribunal held that under the Notification No. TT-2-3401/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 and Notification No. TT-2-1381/XI-9(167)-95-U.P. Act 15-48-Order-96 dated June 6, 1996, balanced cattle feed was excluded from the entry "cattle fodder" and the same was made taxable under the Notification No. TT-2-3403/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994. The Tribunal held that the cattle feed manufactured by the dealer was not balanced cattle feed and was provided to the cattle to increase the taste of the ordinary food and, therefore, was not taxable being still covered under the entry "cattle fodder". The Tribunal held that the cattle feed manufactured by the dealer did not contain any vitamin. Heard Sri B. K. Pandey, the learned Standing Counsel and Sri Kunwar Saksena, learned counsel for the dealer - opposite party. The learned Standing Counsel submitted that the Tribunal has erred in holding that the cattle feed manufactured by the dealer was not balanced cattle feed and was not liable to tax after October 1, 1994. He submitted that from the entry of Notification No. TT-2-3401/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994, cattle feed has been excluded from cattle fodder. The "cattle feed" which was excluded means "cattle feed" in all forms and nature, including balanced cattle feed. Therefore, all kinds of cattle feed which were earlier held to be covered under cattle fodder, being fed by the cattle, in various decisions of this court and apex court have been excluded from the entry "cattle fodder". He submitted that after October 1, 1994 under Notification No. TT-2-3403/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 balanced cattle feed has been made taxable at the rate of five per cent and other cattle feed are liable to tax as an unclassified item at the rate of eight per cent. The learned counsel for the dealer submitted that by Notification No. TT-2-3401/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 from the entry "cattle fodder", balanced cattle feed has only been excluded. The learned counsel for the dealer submitted that by Notification No. TT-2-3401/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 from the entry "cattle fodder", balanced cattle feed has only been excluded. He submitted that the word "balance", which has been used prior to poultry feed also qualifies cattle feed and all other cattle feed has not been excluded with effect from October 1, 1994 and by the Notification No. TT-2-3403/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 balanced cattle feed has only been made taxable. Therefore, cattle feed other than balanced cattle feed was still exempted from tax falls under the entry "cattle fodder", in view of the decision of this court in the case of Commissioner of Trade Tax v. Paras Ram Lakshi Ram reported in [2005] 41 STR 42 and in the case of Cattle Feed Plant, Pradeshik Co-operative Diary Federation Ltd., Meerut v. Commissioner of Trade Tax reported in [2005] 42 STR 819. He submitted that the decision of the learned single judge of this court in the case of Cattle Feed Plant, Pradeshik Co-operative Diary Federation Ltd., Meerut v. Commissioner of Trade Tax [2005] 42 STR 819 has been accepted and followed by the Division Bench in Writ Petition No. 164 of 1989 Liptons India Ltd. v. State of U.P. decided on April 17, 2007 ([2008] 18 VST 148 (All) [App]). He submitted that the Division Bench of this court in the case of Friends Modicon (P.) Ltd. v. State of U.P. reported in [1997] UPTC 427 has held that the cattle feed which increases productivity and consists of concentrate and vitamin is balanced cattle feed. He submitted that unless the feed contains vitamin, it cannot be balanced cattle feed. He further submitted that the feed manufactured by the dealer did not contain vitamins and it mainly contains molasses and are mixed with normal food of the cattle to increase the taste and was not provided as balanced cattle feed to increase the productivity. Having heard the learned counsel for the parties, I have perused the order of the Tribunal and the authorities below. To adjudicate the issue involved, it is necessary to refer the relevant notifications. "Notification No. ST-II-3714/X-6(1)/85-U.P. Act 15/48-Order-85 dated June 5, 1985. (Published in U.P. Gazette, dated June 5, 1985). Having heard the learned counsel for the parties, I have perused the order of the Tribunal and the authorities below. To adjudicate the issue involved, it is necessary to refer the relevant notifications. "Notification No. ST-II-3714/X-6(1)/85-U.P. Act 15/48-Order-85 dated June 5, 1985. (Published in U.P. Gazette, dated June 5, 1985). In exercise of the powers under clause (a) of section 4 of the Uttar Pradesh Sales Tax Act, 1948 (U.P. Act No. XV of 1948), read with section 21 of the Uttar Pradesh General Clauses Act, 1904 (U.P. Act No. 1 of 1904), the Governor is pleased to make, with effect from June 6, 1985, the following amendments in Government Notification No. ST-2-7038/X-7(23)-83-U.P. Act XV/48-Order-85, dated January 31, 1985 : Amendments In the Schedule to the aforesaid notification, - (1) for the existing entries in column 2 against serial numbers 7, 10, 43 and 53, the following entries shall respectively be substituted, namely : 10. Cattle fodder including green fodder, chuni, bhusi, chhilka, chokar, javi (popularly known as ghurjai), gowar, de-oiled oil-cake, de-oiled rice polish, de-oiled rice bran or de-oiled rice husk, but not including oil-cake (khali), rice polish, rice bran or rice husk. "MATTER IN OTHER LANGUAGE" Notification No. TT-2-3401/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994. In exercise of the powers under clause (a) of section 4 of the Uttar Pradesh Sales Tax Act, 1948 (U.P. Act No. 15 of 1948), read with section 21 of the Uttar Pradesh General Clauses Act, 1904 (U.P. Act No. 1 of 1904), the Governor is pleased to make, with effect from October 1, 1994, the following amendment in Government Notification No. ST-2-7038/X-7(23)-83-U.P. Act 15-48-Order-85, dated January 31, 1985 as amended from time to time. Amendments In the Schedule to the aforesaid notification, - (i) ... (ii) ... (iii) for entry at serial No. 10, the following entry shall be substituted namely :- 10. Cattle fodder including green fodder, chuni, bhusi, chhilka, chokar, javi, gowar, de-oiled cake, de-oiled rice polish, de-oiled rice bran or de-oiled rice husk, but excluding oil-cake, rice polish, rice bran, rice husk or balanced poultry feed, cattle feed or fish feed. "MATTER IN OTHER LANGUAGE" Notification No. TT-2-3403/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994. Cattle fodder including green fodder, chuni, bhusi, chhilka, chokar, javi, gowar, de-oiled cake, de-oiled rice polish, de-oiled rice bran or de-oiled rice husk, but excluding oil-cake, rice polish, rice bran, rice husk or balanced poultry feed, cattle feed or fish feed. "MATTER IN OTHER LANGUAGE" Notification No. TT-2-3403/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994. In exercise of the powers under proviso to clause (e) of sub-section (1) of section 3A of the Uttar Pradesh Trade Tax Act, 1948 (U.P. Act No. 15 of 1948), read with section 21 of the Uttar Pradesh General Clauses Act, 1904 (U.P. Act No. 1 of 1904), the Governor is pleased to make the following amendment in Government Notification No. ST-II-5785/X-10(1)/8-U.P. Act 15-48-Order-81, dated September 7, 1981, as amended from time to time : (1) to (4) ... --------------------------------------------------------------------- 56. Balanced cattle feed, poultry feed or M or I 4 per cent." fish feed --------------------------------------------------------------------- The question for consideration in the present revisions is whether the cattle feed manufactured and sold by the dealer consisting of 90 per cent molasses, two per cent urea, one per cent sewar, five per cent ordinary salt and 2 per cent black salt is exempted form tax after October 1, 1994 or liable to tax after October 1, 1994. The issues for consideration are as follows : 1. Whether from the Notification No. TT-2-3401/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 from the entry "cattle fodder" only balanced cattle feed has been excluded or all kinds of cattle feed has been excluded which also includes the balanced cattle feed ? 2. Whether the cattle feed manufactured by the dealer is still covered under the entry "cattle fodder" under the Notification No. TT-2-3401/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 and was exempted from tax ? 3. Whether the cattle feed manufactured by the dealer was balanced cattle feed and liable to tax under the Notification No. TT-2-3403/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 at the rate of five per cent or liable to tax as an unclassified item as not balanced cattle feed ? Issue Nos. 1 and 2. A bare perusal of Notification No. TT-2-3401/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 referred hereinabove both in English and Hindi versions reveals that the cattle feed has been excluded from the entry "cattle fodder". The word "cattle feed" is after "balanced poultry feed". Issue Nos. 1 and 2. A bare perusal of Notification No. TT-2-3401/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 referred hereinabove both in English and Hindi versions reveals that the cattle feed has been excluded from the entry "cattle fodder". The word "cattle feed" is after "balanced poultry feed". Therefore, it is difficult to accept that the word "balanced" which is along with poultry feed also qualifies "cattle feed" and the exclusion is confined to balanced cattle feed only. The language of the entry is plain and unambiguous and there is no reason to give any other interpretation and to add the word "balanced" with the cattle feed which was not there. Further after balanced poultry feed there is a comma and then words "cattle feed" are mentioned, which means that "balanced poultry feed" is one word and "cattle feed" is separate and both are independent. The aforesaid view is supported by the decision of the apex court in the case of Shree Durga Distributors v. State of Karnataka reported in [2007] 7 VST 267; [2007] AIR SCW 2879, paragraph 4. The object of the notification also appears to be to exclude all "cattle feed" which are in concentrate form, or balanced cattle feed or in any other form which are held covered under the entry "cattle fodder" being fed by the cattle, by catena of decisions by this court, other courts and by the apex court. After the exclusion of the cattle feed from the entry "cattle fodder", the exemption on the turnover of cattle feed has been withdrawn with effect from October 1, 1994. The "cattle feed" which has been excluded from the entry "cattle fodder" includes all kinds of, and all forms and nature of cattle feed including the balanced cattle feed. Balanced cattle feed has been classified and made taxable at the rate of five per cent under the Notification No. TT-2-3403/XI-9(116)-94-U.P. Act 15-48-Order-94 dated October 1, 1994 and other cattle feed would be liable to tax as an unclassified item. In support of the aforesaid view it is relevant to refer one paragraph of the Division Bench of this court in Writ Petition No. 164 of 1989, Liptons India Ltd. v. State of U.P. ([2008] 18 VST 148 (All) [App]). "The assessment years involved in this case are 1985-86, 1988-89 and 1989-90. In support of the aforesaid view it is relevant to refer one paragraph of the Division Bench of this court in Writ Petition No. 164 of 1989, Liptons India Ltd. v. State of U.P. ([2008] 18 VST 148 (All) [App]). "The assessment years involved in this case are 1985-86, 1988-89 and 1989-90. All these assessment years are prior to the amendment dated October 10, 1994 by notification No. TT-3041 whereunder "cattle feed" was excluded form "cattle fodder" as mentioned in the entry at serial No. 10 of the notification dated June 5, 1985." In the case of Swadeshi Polytex Ltd. v. Income-tax Officer reported in [1981] 127 ITR 287; [1980] UPTC 1084, the Division Bench of this court held as follows : "... It is well-established that where the language of a section is plain and unambiguous, it is not open to courts to read into it limitation which are not there based on an a priori reasoning, as to the probable intention of the Legislature. Such intention can be gathered from the words actually used in the legislation and what is unexpressed has the same value as to what is unintended. ..." In the case of Commissioner of Sales Tax, Gujarat v. Union Medical Agency reported in [1981] 47 STC 170; [1981] UPTC 520, the apex court held as follows : "... If the meaning of the section is plain, it is to be applied whatever the result." In the case of Assessing Authority-cum-Excise and Taxation Officer, Gurgaon v. East India Cotton Mfg. Co. Ltd. Faridabad reported in [1981] 48 STC 239; [1981] UPTC 1319, the apex court held as follows : "It is a well-settled rule of interpretation that a statute must be construed according to its plain language and neither should anything be added nor subtracted unless there are adequate grounds to justify the inference that the Legislature clearly so intended." In the case of Commissioner of Income-tax, Orissa v. N.C. Budharaja & Company reported in [1993] 91 STC 450 (SC); [1993] 204 ITR 412; [1993] UPTC 1335, the apex court held as follows : "The principle of adopting a liberal interpretation which advances the purpose and object of beneficent provisions cannot be carried to the extent of doing violence to the plain and simple language used in the enactment. It would not be reasonable or permissible for the court to re-write the section or substitute words of its own for the actual words employed by the Legislature in the name of giving effect to the supposed underlying object. After all, the underlying object of any provision has to be gathered on a reasonable interpretation of the language employed by the Legislature." In the case of Gurudevdatta VKSSS Maryadit v. State of Maharashtra reported in [2001] 4 SCC 534, the apex court held as follows : "Further we wish to clarify that it is a cardinal principle of interpretation of statute that the words of a statute must be understood in their natural, ordinarily or popular sense and construed according to their grammatical meaning, unless such construction leads to some absurdity or unless there is something in the context or in the object of the statute to suggest to the contrary. The golden rule is that the words of a statute must prima facie be given their ordinary meaning. It is yet another rule of construction that when the words of the statute are clear, plain and unambiguous, then the courts are bound to give effect to that meaning, irrespective of the consequences. It is said that the words themselves best declare the intention of the law-giver. The courts have adhered to the principle that efforts should be made to give meaning to each and every word used by the Legislature and it is not a sound principle of construction to brush aside words in a statute as being inapposite surpluses, if they can have a proper application in circumstances conceivable within the contemplation of the statute. ..." In this view of the matter, I am of the view that the "cattle feed" manufactured by the dealer is specifically excluded from the entry "cattle fodder" and, therefore, not exempted from tax and liable to tax. ..." In this view of the matter, I am of the view that the "cattle feed" manufactured by the dealer is specifically excluded from the entry "cattle fodder" and, therefore, not exempted from tax and liable to tax. Issue No. 3 In the case of Friends Modicon (P.) Ltd. v. State of U.P. reported in [1997] UPTC 427, the Division Bench of this court held as follows : "The words 'poultry feed' has acquired a definite connotation in livestock farming and so also has the word 'concentrates' and whereas the feed simpliciter is essential for the maintenance of poultry, the concentrates, that is, vitamins in the food-stuff enable the poultry to maintain energy, to perform the vital process of life and provide the material to replace the essential tissues, breakdown of which occurs in the body continuously. From the materials available on the subject, it is by now clear that all food-stuffs are composed of water and organic and mineral matters. Organic matter is composed of proteins, fats, crude fibre and soluble carbohydrates. Besides the above, there are certain substances known as vitamins, which are considered to be essential for the proper nutrition of farm stock. The ration of an animal may be divided for convenience into two parts : (1) maintenance ration, viz., the portion of the diet which just enables the animal at rest to carry on the essential processes of life, such as breathing and circulation of blood, without either gain or loss of weight; and (2) feed supplied over and above the maintenance requirement for augmenting the production for growth or fattening, for production of milk or in the case of poultry for augmenting egg-laying capacity. It is a matter of common knowledge that in the present days when maintenance of the poultry has become so costly, the poultry is not kept in a farm in a state of non-production. To make the poultry financially viable, it is but necessary to supply a balanced poultry feed to increase the production of eggs or fat and growth if the poultry is kept for consumption of its meat. To make the poultry financially viable, it is but necessary to supply a balanced poultry feed to increase the production of eggs or fat and growth if the poultry is kept for consumption of its meat. The feed consists not only of that concentrates, which are essential for the maintenance of life but also other concentrates, which provide the energy required for production and vitamins are considered essential for the proper nutrition of farm stock and some of the vitamins like vitamin A and D have to be supplied to the animals through their feed. If this concept of poultry is borne in mind, it will become clear that the expression 'balanced poultry feeds' is not understood by the people conversant with keeping the poultry as merely consisting of ration for maintenance but also as comprehending ration for production purposes. The feed simpliciter, that is, ration for maintenance cannot be a balanced poultry feed which expression includes a feed full of vitamins and all other ingredients, which augment the production of eggs in the case of poultry. The assessing authority himself took the view that the petitioner deals in feed supplements, that is, the concentrates which are supplied to keep the poultry in a good state of production and which ensure over all improvement in the general health of the poultry. From these facts, it is manifest that without concentrates, the ordinary feed which is given only for maintenance purposes, cannot be said to be a balanced poultry feed. To make the poultry feed, a balanced poultry feed, it is essential to include the vitamins or concentrates. So, it is addition of concentrates in the poultry feed which makes it a balanced poultry feed. Short of vitamins or the concentrates, the poultry feed cannot be said to be a balanced poultry feed." In the aforesaid case, the Division Bench of this court held that the feed simpliciter, that is, ration for maintenance cannot be a balanced poultry feed which expression includes a feed full of vitamins and all other ingredients, which augment the production of eggs in the case of poultry. Further, it has been held that to make the poultry feed, a balanced poultry feed, it is essential to include the vitamins or concentrates. So, it is addition of concentrates in the poultry feed which makes it a balanced poultry feed. Further, it has been held that to make the poultry feed, a balanced poultry feed, it is essential to include the vitamins or concentrates. So, it is addition of concentrates in the poultry feed which makes it a balanced poultry feed. Short of vitamins or the concentrates, the poultry feed cannot be said to be a balanced poultry feed. It means that for a balanced feed, it is essential that there should be vitamins and concentrates which augment the production. Therefore, if in feeds there are such concentrates which augment the production, it will be a balanced cattle feed even though, there are no vitamins. It may be mentioned here that the presence of vitamins by name is not essential. It may be possible that vitamins are available in the constituent of the product. The nature of the constituent can only be worked out by chemical analysis. In the present case, without chemical analysis, opinion has been formed that there was no vitamins. Further, the Tribunal has also not considered whether the cattle feed manufactured by the dealer increases the production or not. This aspect of the matter has not been examined. In this view of the matter, I am of the opinion, that the matter requires further adjudication. It is to be enquired whether the constituents of product includes vitamins, concentrate and increases productivity. This is possible only by chemical analysis, which is to be carried on by the experts. On the facts and circumstances, the Tribunal is directed to get the product chemically examined and get the expert opinion whether it increases the productivity and to decide whether it is the balanced cattle feed or other than balanced cattle feed. Decision on issue No. 3 depends upon the result of the chemical analysis and the opinion of the expert as to whether the cattle feed manufactured by the dealer is a balanced cattle feed or other than the balanced cattle feed. It will be open to the Tribunal to adjudicate the aforesaid questions at its own stage or if, Tribunal may like the matter may be sent back to the assessing officer for adjudication. In the result, both the revisions are allowed. The order of the Tribunal is set aside and the matter is remanded back to the Tribunal to decide the appeals afresh in the light of the observations made above.