JUDGMENT RAJES KUMAR, J. - These three revisions under section 11 of the U.P. Trade Tax Act, 1948 (hereinafter referred to as "the Act") are directed against the order of Tribunal dated January 18, 2006 relating to the assessment years 1990-91, 1991-92 and 1992-93. The applicant is a co-operative society, engaged in the business of manufacture and sale of milk, ghee, paneer and cream, etc. In all the three revisions the dispute relates to the taxability of such milk, which according to the applicant was milk prepared by mixing of white butter and milk powder in natural milk to increase the quality of milk. It was claimed that the applicant was selling the milk of specified standard and to maintain the said standard in the milk white butter and milk powder, etc., have been added. For the assessment year 1990-91 the assessing authority granted the exemption on the sale of such milk in the original assessment proceeding. Subsequently, reassessment proceeding under section 21 of the Act was initiated and the tax had been assessed on the sale of such milk on the ground that the exemption was not admissible to the artificial milk under section 4 of the Act but was admissible to the natural milk. Likewise for the assessment years 1991-92 and 1992-93 in the original assessment proceeding such milk had been assessed to tax. First appeals filed by the applicant were rejected. The applicant filed second appeals before the Tribunal, which were also dismissed vide order dated January 18, 1998. Being aggrieved by the said order, applicant filed trade tax revisions before this court. All the revisions were allowed by this court vide order dated March 9, 2005 and the matters were remanded back to the Tribunal to decide the dispute afresh in the light of the decisions of this court in the case of Commissioner of Trade Tax v. Nainital Dugdh Utpadan Sahkari Sangh Ltd. Nainital reported in [2001] UPTC 328 and Indodan Milk Products Ltd., Muzaffarnagar v. Commissioner of Sales Tax reported in [1974] 33 STC 381; [1973] UPTC 569. This court has further observed that "what has to be examined is whether by mixing milk powder, white butter and cream, etc., in the purchased milk alleged to improve the quality of milk, the item obtained, remains milk". The Tribunal by the impugned order dismissed all the three appeals. This court has further observed that "what has to be examined is whether by mixing milk powder, white butter and cream, etc., in the purchased milk alleged to improve the quality of milk, the item obtained, remains milk". The Tribunal by the impugned order dismissed all the three appeals. The Tribunal in its order disputed the case of the applicant on the ground that in reply to the show-cause notice, the applicant stated that by mixing white butter and milk powder, etc., milk had been prepared and further no evidence had been adduced that on the purchased milk, milk powder and white butter had been mixed to increase the quality. The Tribunal held that the milk sold by the applicant was artificial milk manufactured by mixing white butter and milk powder and, therefore, such milk was not liable for exemption under section 4 of the Act. The decision of this court in the case of Commissioner of Trade Tax v. Nainital Dugdh Utpadan Sahkari Sangh Ltd., Nainital reported in [2001] UPTC 328 was distinguished on the ground that in that case it was held that after mixing milk powder, it remains milk. While in the present case, artificial milk has been prepared by mixing milk powder, white butter and cream, etc. Heard the learned counsel for the parties. The learned counsel for the applicant submitted that the Tribunal has erred in observing that the applicant had manufactured artificial milk by mixing white butter, milk powder and cream, etc., and has disputed the case of the applicant that in the milk white butter, milk powder and cream, etc., were added to increase the quality of the milk. He submitted that the aforesaid inference has been drawn by the Tribunal on the basis of the reply given by the applicant to the show-cause notice and on the ground that no evidence had been adduced in this regard. He submitted that the view of the Tribunal in this regard is misplaced and contrary to the record. He submitted that in reply to the show-cause notice the applicant had categorically stated that in the milk, milk powder, white butter and cream, etc., had been added to increase the quality of the milk. The details of the milk purchased during the year under consideration had been furnished before the assessing authority along with the reply to the show-cause notice, which is on record. The details of the milk purchased during the year under consideration had been furnished before the assessing authority along with the reply to the show-cause notice, which is on record. He further submitted that the milk is a generic word, which includes both natural milk as well as artificial milk. Therefore, even the artificial milk is milk and exempted under section 4 of the Act. In support of his contention he relied upon the Full Bench decision of this court in the case of Indodan Milk Products Ltd., Muzaffarnagar v. Commissioner of Sales Tax reported in [1974] 33 STC 381; [1973] UPTC 569. He further submitted that the Explanation (b) of section 4 of the Act has been substituted by the U.P. Act No. 35 of 2000, dated January 31, 2000 in which reconstituted on recombined milk prepared from skimmed milk, butter or butter oil has been included in milk. He submitted that the amendment in the Explanation is clarificatory in nature and to be made applicable even for a period prior to November 1, 2000. The learned Standing Counsel relied upon the order of the Tribunal. Having heard the learned counsel for the parties, I have perused the order of the Tribunal and the authorities below. I have also perused the assessment records. In the assessment records, replies to the show-cause notices are available on record. For the assessment year 1990-91 show-cause notice was issued on July 14, 1995 in which it has been alleged that milk powder, cream and white butter had been purchased and out of which milk had been manufactured and why it should not be taxed as an unclassified item. It appears that no reply has been filed. Perusal of the assessment record reveals that in reply to the show-cause notice dated November 7, 1994 the applicant had filed the reply, in which it was stated that the milk had been purchased through small societies of the village. The purchases had been made on the basis of the percentage of fat and SNF. It was further stated that the sale of milk was made with nine per cent of SNF and the purchases were made with eight per cent, - Nine per cent of SNF and, therefore, to meet the deficiency, milk powder, etc., were added. In the assessment record of assessment year 1991-92, reply dated March 7, 1996 is available on record. It was further stated that the sale of milk was made with nine per cent of SNF and the purchases were made with eight per cent, - Nine per cent of SNF and, therefore, to meet the deficiency, milk powder, etc., were added. In the assessment record of assessment year 1991-92, reply dated March 7, 1996 is available on record. In para two of the reply it was stated that the milk had been purchased through small societies and the payments were made on the basis of percentage of fat and SNF and to achieve the standard of percentage of fat and SNF, white butter and WMP had been used. It was further stated that the milk powder and white butter had been used to increase the required percentage and no artificial milk was prepared. A chart was also annexed showing the details of the milk purchased and the items mixed in the milk. Similar reply was also given in the assessment year 1992-93, which is dated March 22, 1996. Thus, the Tribunal is wrong in saying that the applicant had manufactured artificial milk by mixing milk powder, white butter, etc. It also appears that to increase the required percentage of fat and SNF, white butter and milk powder had been added in the milk. Such milk was sold as milk. Therefore, the Tribunal is wrong in saying that the applicant had manufactured artificial milk by mixing milk powder and white butter, etc. In the case of Commissioner of Trade Tax v. Nainital Dugdh Utpadan Sahkari Sangh Ltd., Nainital reported in [2001] UPTC 328 it has been held by this court that after mixing milk powder in the milk, it remains milk and exempted from tax under section 4 of the Act. Under section 4(a) of the Act sale or purchase of milk is exempted. Under section 4(a) of the Act sale or purchase of milk is exempted. Clause (b) of Explanation prior to amendment by the U.P. Act No. 35 of 2000 and subsequent to the U.P. Act No. 35 of 2000 read as follows : "Explanation (b) to section 4 of the Act prior to amendment by U.P. Act No. 35 of 2000 : 'milk does not include condensed milk, powder or baby milk.'" After the amendment by U.P. Act No. 35 of 2000 : "milk includes reconstituted or recombined milk prepared from skimmed milk powder, butter or butter oil but does not include condensed milk, powder or baby milk." In the Explanation (b) of section 4 of the Act only condensed milk powder or baby milk has been excluded from milk. Artificial milk, reconstituted or recombined milk have not been excluded. It is settled principle of law that natural meaning of word should be given, if there is no ambiguity. Milk is a generic word, which includes milk of all nature provided it is bought and sold as milk and in common parlance and in commercial sense it is known as milk. There appears to be no reason to restrict milk, to the natural milk only. Full Bench of this court held that condensed milk is milk and exempted from tax under section 4(a) of the Act. In the case of Indodan Milk Products Ltd., Muzaffarnagar v. Commissioner of Sales Tax reported in [1974] 33 STC 381; [1973] UPTC 569, question for consideration before the Full Bench of this court was whether the condensed milk is a milk. The Full Bench of this court held as follows : "22. Learned Standing Counsel contended that in section 4(a) expression used is milk and not milk in any form. In the circumstances, the observations made by the Supreme Court in State of Gujarat v. Sakarwala Brothers [1967] 19 STC 24 cannot support the dealer. I am unable to accept this submission. As stated earlier, there is no justification limiting the meaning of the expression 'milk' as used in section 4(a) of the U.P. Sales Tax Act to milk obtained in its natural form only. In my opinion, the expression 'milk' in section 4(a) means milk in any form just as the expression 'sugar' in entry 47 of Schedule A to the Central Excises and Salt Act, 1944 means sugar in any form. In my opinion, the expression 'milk' in section 4(a) means milk in any form just as the expression 'sugar' in entry 47 of Schedule A to the Central Excises and Salt Act, 1944 means sugar in any form. I am, accordingly, of opinion that the aforementioned Supreme Court cases support the view that condensed milk is milk within the meaning of section 4(a) of the U.P. Sales Tax Act. ... 24. It may be that milk in its natural form may be a commercial commodity different from milk in condensed form but, as stated earlier, there is no justification for holding that section 4(a) grants exemption for the sale of milk only when it is sold in the same condition in which it is obtained from the mammary glands of cow and buffalo. The exemption under section 4(a) has been granted on sale of milk in any form and, therefore, even if various forms of milk are different commercial commodities, the exemption given in section 4 equally applies to all those commodities. I am accordingly of opinion that the cases relied upon by the learned Standing Counsel do not go to show that condensed milk is not milk within the meaning of section 4(a) of the U.P. Sales Tax Act." This court held that there is no justification to limiting the meaning of expression milk as used in section 4(a) of the Act to milk obtained in its natural form only. The exemption under section 4(a) of the Act has been granted on the sale of milk which in my view include milk of all nature. Therefore, even if various nature of milks are different commercial commodities, the expression "milk" in section 4(a) of the Act equally applies to all those commodities. In this view of the matter I find no reason in denying the exemption to the artificial milk, reconstituted or recombined milk prepared by mixing of milk powder, butter and butter oil, etc. In view of the aforesaid view, it is not necessary to go into the question whether the Explanation which has been added subsequently is clarificatory or not. In the result, all the three revisions are allowed. Order of the Tribunal is set aside and it is held that the milk sold by the applicant after adding milk powder, white butter, etc., was exempted from tax. In the result, all the three revisions are allowed. Order of the Tribunal is set aside and it is held that the milk sold by the applicant after adding milk powder, white butter, etc., was exempted from tax. The Tribunal is directed to pass appropriate order under section 11(8) of the Act.