ORDER Ravi Malimath , J.—The petition is by the State being aggrieved by the order of the Tribunal, wherein the appeal filed by the assessee was allowed by granting the benefit of reduction at two per cent in the rate of Central sales tax. The assessee operates a solvent extraction plant in Challakere and carries the business of manufacture and sale of solvent extracted oil. By products of de-oiled cake and de-oiled rice bran are obtained in the manufacturing process. Business is carried on also for purchase and sale of edible oils and oil cakes. For the assessment year ending March 31, 2003, the assessee filed a return of turnover under the Central Sales Tax Act, 1956 declaring total and taxable turnovers while admitting liability of tax at two per cent on the sale of sunflower de-oiled cake in the course of inter-State trade and commerce. The assessing authority reopened the assessment and in terms of the provisions of section 9(2) of the Central Sales Tax Act, 1956 read with section 12A of the Karnataka Sales Tax Act, 1957 held that there was an escapement of tax due to the reason that the inter-State sales of sunflower de-oiled cake was liable to tax at four per cent and not at two per cent as erroneously adopted and accordingly, assessments were concluded. Aggrieved by the same, an appeal was preferred before the Joint Commissioner of Commercial Taxes (Appeals), who allowed the appeal by setting aside the order of the assessing authority. Consequently, the original order dated January 29, 2005 was restored. Aggrieved by the same, the assessee preferred an appeal before the Tribunal. The Tribunal by the impugned order allowed the appeal by modifying the reassessment order of the first appellate authority and accordingly, the benefit of reduction of two per cent Central sales tax was granted to the assessee. Aggrieved by the same, the State has filed the present revision. 2. By the order dated December 7, 2009, the appeal was admitted to consider the following substantial questions of law : (1) Whether, on the facts and in the circumstances of the case, can it be held that the order dated July 12, 2007 passed by the Karnataka Appellate Tribunal in S. T. A. No. 425 of 2006 allowing the appeal is correct and in accordance with law ? (2) Whether on the facts and in the circumstances of the case, can it be held that the Appellate Tribunal was right in law in ignoring that under the Karnataka Sales Tax Act in the Second Schedule in serial No. 1 of Part O, oil cake and de-oiled cake are listed under two separate sub-headings as two different commodities ? 3. The Government of Karnataka in exercise of powers conferred by section 8(5) of the Central Sales Tax Act, 1956 issued Notification No. FD 119 CSL 2002 (2) dated May 31, 2002 granting reduction in the rate of Central sales tax payable on inter-State sales to two per cent on the goods specified, subject to conditions. The goods mentioned therein was de-oiled cake, which earlier attracted four per cent tax. The assessee had sold oiled cake also in the course of inter-State trade and commerce. Hence, he claimed the benefit of reduction of Central sales tax from four per cent to two per cent in terms of the notification dated May 31, 2002 for oiled cake on the ground that oil cake and de-oiled cake are one and the same. 4. In terms of the notification dated May 31, 2002, the rate of tax on de-oiled cake was reduced from four per cent to two per cent. The said Schedule contains oil-cake as well as de-oiled cake. In terms of notification dated May 31, 2002, it is only de-oiled cake wherein the rate of tax has been reduced from four per cent to two per cent. But the sale of oiled cake is not covered under the notification. 5. The learned counsel appearing for the respondent contends that the oil cake and de-oiled cake are one and the same and therefore, he pleads that the oil cake and de-oiled cake should be understood in common parlance as understood by a common man. But the sale of oiled cake is not covered under the notification. 5. The learned counsel appearing for the respondent contends that the oil cake and de-oiled cake are one and the same and therefore, he pleads that the oil cake and de-oiled cake should be understood in common parlance as understood by a common man. In support of his contention, he relies on the judgment of this court in the case of Habeeb Proteins & Fats Extracts, Hiriyur, Chitradurga District v. Commissioner of Commercial Taxes, Bangalore reported in (2007) 6 VST 87 (Karn); (2005) 58 Kar L.J. 155 (HC)(DB), wherein it was held that "where de-oiled cake remaining after extraction of oil from oil cake purchased, does not lose its identity as oil cake, it cannot be held that oil purchased has been consumed or has ceased to exist as oil cake." Consequently, purchase tax was not leviable on purchase of oil cake. The facts, circumstances and law declared in the said case are totally alien to the facts of the present case. The court was dealing with the levy of purchase tax and as an obiter a passing reference was made. There is no finding recorded in the said judgment that oil cake and de-oiled cake constitutes the same commodity. That oil cake contains a certain percentage of oil and several other ingredients. When these commodities are subjected to processing of extraction of oil, some quantum of oil is removed but they continue to remain as oil cakes with lesser content of oil. The judgment relied on by the learned counsel appearing for the respondent is not applicable to the case on hand and we are unable to accept the said contention. The facts and circumstances of the case involved in the above referred judgment are totally different compared to the facts and circumstances of the present case. The said case has no bearing on the case on hand. Reliance was also placed on the judgment in the case of Sterling Foods, A Partnership Firm represented by its Partner Shri Ramesh Dalpatram Vs. State of Karnataka and Another, AIR 1986 SC 1809 to contend that the nature of the commodity is to be determined in the same way as in the eyes of the person dealing in it. The said case was with reference to frozen shrimps, prawns and lobsters. State of Karnataka and Another, AIR 1986 SC 1809 to contend that the nature of the commodity is to be determined in the same way as in the eyes of the person dealing in it. The said case was with reference to frozen shrimps, prawns and lobsters. The facts therein are not in consonance with the facts of the present case. 6. In the instant case, the distinction is between the oil cake and de-oiled cake and they are the two different commodities and they are not one and the same. The oil cake contains a certain percentage of oil and other ingredients and when these commodities are subjected to processing of extraction of oil, some quantum of oil is removed but they continue to remain as oil cakes with lesser content of oil. Therefore, to contend that both commodities are same commodities and are to be taxed in the same bracket cannot be accepted. 7. The contention that the commodities will have to be understood in common parlance as understood by a common man is even harder to accept. What a common man understands need not necessarily mean what is understood in accordance with law. In the instant case, the framers of the Schedule were aware of the distinction between oil cake and de-oiled cake. Accordingly, they have treated it as two different commodities. Therefore, to hold that the view of a common man has to necessarily over ride the view of the Legislature is difficult to accept. The distinction in law has been made which requires to be followed. Oil cake and de-oiled cake are two different commodities. The benefit granted to oil cake cannot stand extended to de-oiled cake. The impact of the notification reducing the tax impact was very well known when the benefit was granted. A notification has to be strictly construed. The court cannot read into the notification what is not there. The notification is clear and unambiguous. Any attempt to read it otherwise is not only uncalled for but would amount to redrafting the notification. 8. An identical issue came up for consideration in the case of State of Karnataka v. N. K. Agro Oils (P) Ltd. (2011) 44 VST 345 (Karn). The notification is clear and unambiguous. Any attempt to read it otherwise is not only uncalled for but would amount to redrafting the notification. 8. An identical issue came up for consideration in the case of State of Karnataka v. N. K. Agro Oils (P) Ltd. (2011) 44 VST 345 (Karn). The Division Bench of this court by an order dated June 29, 2011 came to the conclusion that by the very notification dated May 31, 2002 the rate of tax was reduced from four per cent to two per cent in only so far as oiled cake is concerned and no other interpretation can be imported into it. The same is applicable to the present case also. Hence, on this ground also, the Tribunal committed an error in allowing the benefit and extending the benefit of the notification to the assessee in so far as de-oiled cake is concerned. Hence, we are of the view that the order passed by the Tribunal requires to be set aside. For the aforesaid reasons, the questions of law are answered in favour of the Revenue and against the assessee. Consequently, the order dated July 12, 2007 passed by the Tribunal in S. T. A. No. 425 of 2006 is set aside and the order passed by the assessing authority imposing tax at the rate of four per cent in terms of notification dated May 31, 2002 is restored.