JUDGMENT PRAKASH KRISHNA, J. :- The only point mooted in the present revision filed by the Commissioner of Trade Tax against the order of the learned Tribunal passed in second appeal No. 181 of 1998 for the assessment year 1993-94, is whether the tribunal has rightly held that the liquid glucose is taxable as medicine. The facts of the case are not much in dispute and lie in a narrow compass. The dispute relates to the assessment year 1993-94. The dealer opposite party carries on the business of purchasing and selling of liquid glucose, maize starch, Essence. The dispute in the present revision, as noted above, is confined to the rate of taxability of liquid glucose. The acceptance of the account books is also not in question. The assessing authority after rejecting the contention of the dealer that it is nothing but a medicine, held that the liquid glucose is taxable at the rate of 10 per cent under the residuary entry being unclassified item by the order dated 20th of August, 1997. The said part of the order was confirmed in appeal but has been set aside by the tribunal by the order under revision. In the memo of revision the following questions of law have been raised :- A. Whether on the facts and in the light of the circumstances of the case, the Trade Tax Tribunal is legally justified in holding the liquid glucose as medicine despite the fact liquid glucose was neither purchased from medicine dealer nor sold to medicine dealer and Tribunal taxed a part of turnover as unclassified item contrary to its own view ? B. Whether, on the facts and in the circumstances of the case, the Tribunal is justified to hold that Maize Starch is a commodity of Atta, Maida, Suji while in the case of M/s. Raghunath Dass Badhu Dayal v. Commissioner, Trade Tax U.P. (I.T.R. No. 593 dated 3.12.85) the Hon'ble High Court has held that Maize Starch is a cloth washing commodity, it is not a commodity of Atta, Maida, Suji ? So far as the question No. B is concerned, Shri B. K. Pandey, learned standing counsel, submits that the said question does not arise out of the order of the Tribunal and he did not press the same during the course of argument. So far as the question No. B is concerned, Shri B. K. Pandey, learned standing counsel, submits that the said question does not arise out of the order of the Tribunal and he did not press the same during the course of argument. The argument was confined with regard to the question No. A. The contention of the learned standing counsel for the department is that the liquid glucose has been wrongly treated as medicine by the tribunal as the said item is being sold by the dealer opposite party for the manufacturers of bakery confectionery, tobacco etc. The learned counsel for the dealer opposite party, on the other hand, submits that the commodity in question has been rightly held so as medicine and while doing so, the tribunal has rightly taken into consideration the circular dated 23rd of May, 1997 referred to in the order of the tribunal as also the fact that in the purchase and sale vouchers the dealer has treated it as medicine. Considered the respective submissions of the learned counsel for the parties and perused the record. On scrutiny of the account books of the dealer, the assessing authority found that the dealer has sold the liquid glucose to the manufacturers of toffee and biscuits. It has not been sold as medicine. It has been further found that the liquid glucose is not a medicine as the same has been sold in drums and was not manufactured by the manufacturer having license to manufacture the drugs. In the manufacturing of liquid glucose no license under the Drug Control Act is required. Reference was made to a judgement of this Court in CST v. Hindustan Chemicals Company 1986 U.P.T.C. 534 wherein it has been held that liquid glucose is not a chemical. The findings, as noted above, recorded by the Assessing Officer and confirmed by the first appellate authority have not been reversed or modified by the tribunal. A bare perusal of the order of the tribunal would show that it has treated the said commodity as medicine primarily on two grounds, firstly, the sugar contents in the commodity in question is very low and that the manufacturer of the commodity is a license holder under the Prevention of Food Adulteration Act. A bare perusal of the order of the tribunal would show that it has treated the said commodity as medicine primarily on two grounds, firstly, the sugar contents in the commodity in question is very low and that the manufacturer of the commodity is a license holder under the Prevention of Food Adulteration Act. In the sale and purchase vouchers of the commodity in question, the trade tax has been charged at the rate of 7.5 per cent, the rate which is applicable to the drugs. To say the least, the said approach of the tribunal to the issue involved herein is far from satisfactory and the order of the tribunal cannot be sustained. Obtaining of a license for the purpose of manufacturing an article under Prevention of Food Adulteration Act does not amount that the manufactured article is a drug or medicine. The tribunal has not said even a word in the order that the manufacturer of liquid glucose had a drug manufacturing license. Obtaining of a license under the Act is one thing and whether the said license authorises the manufacturer to manufacture drug and medicine is a different thing. The second reasoning given by the tribunal is that the percentage of glucose in the article in question is less than 90%. It is manufactured out of maize wherein the percentage of glucose is very low. It has come on the record that the syrup of liquid glucose is used in the production of jam, jelly and bakery items. The assessing authority has recorded a finding that the article in question is not sold in bottles but in drums. The said item is different from the glucose which are sold in bottles and administered to the patients. The glucose sold in bottles are medicated one and only such glucose can be treated as a medicine. But the glucose sold by the dealer opposite party was obtained from Bharat Starch and Chemicals Yamuna Nagar which is not a unit manufacturing medicine or drug. It has not been found even by the tribunal that said unit is manufacturer of drugs. But the glucose sold by the dealer opposite party was obtained from Bharat Starch and Chemicals Yamuna Nagar which is not a unit manufacturing medicine or drug. It has not been found even by the tribunal that said unit is manufacturer of drugs. In interpreting items in statutes like the Excise Tax Act or Sales Tax Acts, whose primary object is to raise revenue and for which purpose they classify diverse products, articles and substances, resort should be had not to the scientific and technical meaning of the terms or expressions used but to their popular meaning, that is to say, the meaning attached to them by those dealing in them. If any term or expression has been defined in the enactment then it must be understood in the sense in which it is defined but in the absence of any definition being given in the enactment the meaning of the term in common parlance or commercial parlance has to be adopted. The Apex Court in M/s. Indo International Industries v. C.S.T. 1981 U.P.T.C. 481 has held that the words used in statutes like sales tax should be understood in commercial sense. In this case a controversy arose as to whether clinical syringes would be recorded as glassware. The Apex Court has held that as per the dictionary meaning of word glassware, clinical syringes are glassware. However, in commercial sense glassware could never comprise an article like clinical syringes, thermometers, lactometers and similar items having specialised significance and utility. In popular or commercial parlance a general merchant dealing in glassware does not ordinarily deal in clinical syringes, thermometers, lactometers etc. which articles though made of glass are normally available in medical stores or with manufacturers thereof like the assessee therein. Applying the above principle to the facts of the present case and keeping in view the ultimate user of the article in question i.e. the liquid glucose, it is beyond imagination to treat the commodity in question liquid glucose as drugs or medicine administered to the patients sold in bottles through the medical shops and hospitals. The commodity in question is neither being manufactured by medicine or drug manufacturer nor is being dealt with by the persons dealing in medicine nor it is being used as medicine by the consumers. Whether the commodity has got any therapeutic value or not, has not been canvassed or found by the tribunal even. The commodity in question is neither being manufactured by medicine or drug manufacturer nor is being dealt with by the persons dealing in medicine nor it is being used as medicine by the consumers. Whether the commodity has got any therapeutic value or not, has not been canvassed or found by the tribunal even. The sale of article to the manufacturer of toffees and bakery man, negates the claim that the article is medicine. The matter has been dealt with in great detail in M/s. Ponds India Ltd. v. C.T.T. 2008 NTN (37) 169 wherein it has been held by the Apex Court that petroleum jelly is a drug. In this case the Apex Court has taken into consideration the provisions of Drugs and Cosmetics Act, 1940 as also the fact that license was granted to the dealer therein under the Drugs and Cosmetics Act which is not so in the present case. Viewed as above, the order of the tribunal is indefensible and cannot be sustained. The revision succeeds and is allowed. The order of the tribunal under the revision is hereby set aside and the second appeal No. 181 of 1998 filed before the tribunal stands dismissed. No order as to costs.