JUDGMENT PRAKASH KRISHNA, J. - The present revision is directed against the order dated June 27, 2000 passed by the Trade Tax Tribunal in Second Appeal No. 355 of 1999 relevant to the assessment year 1996-97 (U.P.). The facts are not much in dispute. The dealer - opposite party carries on the business of manufacture and sale of khandsari sugar, molasses, rab, etc. He applied for and was granted under compounding scheme to pay a lump sum amount as framed by the State Government under section 7D of the U.P. Trade Tax Act, 1948 instead on actual turnover. Under the compounding scheme, the dealer is entitled to apply for compounding of turnover on "rab galavat" and "rab salavat". It is not in dispute that the dealer - opposite party also sold "rab sayar". It was contended by the dealer - opposite party in the assessment proceeding that the said item is also covered under the scheme. The said plea was not found favour by the assessing authority. However, in the appeal, the first appellate authority was of the view that the turnover of "rab sayar" is also covered under the said compounding scheme and consequently, it set aside the assessment order creating demand of Rs. 28,554 as tax. The order of the first appellate authority has been confirmed by the Tribunal by the order under revision. Heard Sri B. K. Pandey, learned standing counsel for the Department. None is present on behalf of the dealer - opposite party. In the memo of revision, the following questions of law have been sought to be raised : (i) Whether, on the facts and in the circumstances of the case, the Trade Tax Tribunal is legally justified to set aside the tax imposed on the sale of rab sayar despite the fact Rab Sayar is not included in the compounding scheme for cane crushers ? (ii) Whether, on the facts and in the circumstances of the case, the Trade Tax Tribunal is legally justified to hold that rab sayar, rab galavat and rab salavat are one and the same thing for the purpose of compounding scheme issued for cane crushers ? The learned standing counsel for the Department submits that the compounding scheme is in the nature of an agreement. No authority can enhance the scope of the said scheme. The learned standing counsel for the Department submits that the compounding scheme is in the nature of an agreement. No authority can enhance the scope of the said scheme. He submits that indisputably, "rab sayar" is not covered under the said scheme, therefore, the dealer is liable to pay the tax on the turnover of "rab sayar". I have given careful consideration to the above submission of the learned standing counsel and I find sufficient force therein. It may be noted that none of the authorities below has found that "rab sayar" is also included in the said compounding scheme. The Tribunal has proceeded to decide the controversy against the Department on the basis of Explanation I(b) to section 3D(8) of the U.P. Trade Tax Act, 1948. The said Explanation reads as follows : "Explanation I : For the purposes of this Act, the following goods shall be deemed to be different from each other, namely. - (a) Khandsari molasses, including sheera-saya, sheera-galavat and sheera-salavat; (b) Rab, including rab-sayar, rab-galavat and rab-salavat; (c) Gur-lauta and gur-raskat; and accordingly, nothing in this section shall be construed to prevent the imposition, levy or collection of tax under section 3A in respect of any one of the said goods merely because tax has been imposed, levied or collected under this section in respect of any other of them, or vice versa." In my considered view, the said Explanation does not support the view which has been taken by the Tribunal. In view of the fact that the said item is not covered under the compounding scheme, no authority can increase the ambit and scope of the scheme by adopting process of interpretation. The Explanation given to section 3D is for the purposes of the Act. The very fact that the compounding has been provided for rab, rab galavat and rab salavat is indicative of the fact that under it rab sayar is not covered purposely otherwise there was no necessity to mention rab galavat and rab salavat in the notification. In view of the above, I find sufficient force in the argument of the learned standing counsel. The order of the Tribunal is liable to be set aside. The revision succeeds and is allowed. The order of the Tribunal under revision is hereby set aside and the assessment order is restored. No order as to costs.