RASTOGI, J. - (1.) THIS is the Commissioner's revision under section 11(1) of the U.P. Sales Tax Act and the short question for consideration is as to whether tartaric acid is a chemical or a medicine. The respondent-assessee, a limited company, is a dealer in chemicals, medicines, etc., as also carries on manufacture of medicines. In assessment to sales tax for the assessment year 1971-72 the assessee claimed that its turnover in respect of tartaric acid was liable to tax as medicine under entry No. 5 of the schedule to Notification No. ST-3609/X - 900(21)-69 dated 1st July, 1969, as subsequently amended with effect from 15th November, 1971, by Notification No. ST-II-332/X - 1012-1971 dated 15th November, 1971, in the schedule to which it is at S. No. 55, the rate of tax being 3 paise per rupee and 3 per cent in these two notifications respectively, leviable at single point. The Sales Tax Officer did not accept this contention and treated tartaric acid as chemical within the meaning of entry No. 4, "chemicals of all kinds other than soda ash", of the schedule to Notification No. ST-3391/X - 1012-1962 dated 1st July, 1962, as amended by Notification No. ST-II-332 dated 15th November, 1971, in the schedule to which it is entry No. 21, "chemicals of all kinds including fuel gases such as Burshane and Indane but excluding soda ash and caustic soda", the rate being 7 paise per rupee and 7 per cent in these two notifications respectively, leviable at single point. The assessee appealed. The Assistant Commissioner (Judicial) accepted the assessee's contention and treated tartaric acid as falling in the category of medicines. The Commissioner then applied in revision and the Additional Judge (Revisions), Sales Tax, took the same view, hence this further revision. According to the learned standing counsel the view taken by the appellate and the revising authorities that since this commodity was sold by the assessee to chemists who used it in the manufacture of medicines, it fell in the category of medicines was erroneous because the purpose for which a commodity is sold is not decisive of the matter and in a way it is a negative approach. What was relevant consideration was whether or not the assessee had sold this commodity as medicine and since the assessee had not done so, it could not be treated as medicine. My attention was invited to the dictionary meaning given to tartaric acid as also to Encyclopaedia Britannica in which tartaric acid has been described as a chemical and pertaining to chemistry. My attention was also invited to a large number of cases to which I shall refer a little later. In any opinion, the question should be examined from three aspects : Firstly what is the sense in which this commodity is understood by persons dealing with it; secondly what is the main use of this commodity and lastly, the purpose for which it was sold by the assessee. All the three aspects are interconnected and hence are being considered together. Admittedly the assessee carried on business in chemicals, medicines and also in the manufacture of medicines. It had been granted a licence under the relevant provisions of the Drugs Rules, 1945, and that licence is for the manufacture of certain categories of drugs which are described in the schedule attached to the licence. A photostat copy of that licence was produced before me. Apart from this the assessee furnished a list of the sales made of this commodity and those sales were made to dealers carrying on business in purchase and sales of medicines. I agree with the learned counsel for the assessee that thus there was evidence given to show the purpose for which this commodity had been sold and there was no evidence to the contrary to show that it was sold as chemical. The mere fact that this commodity can be used as a chemical also or that some processing is required for making it a medicinal preparation, in my opinion, would not alter the classification to which it belongs. Now instead of referring to the dictionary meaning of this substance, it would be more purposeful if the sense in which it is understood in the medical world is considered. In British Pharmaceutical Code (1973 Edition) issued by the authority of the Pharmaceutical Society of Great Britain, the composition of tartaric acid is described as under : "Tartaric acid is (+) - tartaric acid and may be obtained from argol, the crude potassium hydrogen tartrate deposited during the fermentation of grape juice." As for its action and uses it is stated : "Tartaric acid is a saline purgative which has actions similar to those described under sodium potassium tartrate. It is a constituent of effervescent powders and granules and of cooling drinks and should be taken well-diluted with water (page 494)." Sodium potassium tartrate has been described as a saline purgative; actions and uses of it are described as magnesium sulphate. It causes a watery evacuation of the bowel without producing irritation (page 461). The uses of magnesium sulphate are described as : "Magnesium sulphate is a saline purgative. Such purgative are not readily absorbed from the intestine. When taken by mouth in dilute solution they reduce the normal absorption of water from the intestine with the result that the bulky fluid contents distend the bowel, active reflex peristalsis is excited, and evacuation of the contents of the intestine occurs in one to two hours." Saline purgatives are often given in habitual constipation due to deficient peristalsis. It would be seen, therefore, that according to the treatise tartaric acid is a saline purgative and is administered well-diluted with water and the effect is to relieve constipation. I do not think that after the above actions and use of tartaric acid any doubt can be entertained that tartaric acid is not a medicine. It may be a chemical which word is a of a wider import but when there is specific entry about it, it is the special entry which is to cover the levy and rate of tax and not the general entry. In Commissioner of Sales Tax v. Prayag Chemical Works [1970] 25 STC 85 (FB), it has been laid down that whether a commodity can be described as chemical for the purposes of entry in Notification No. ST-905/X dated 31st March, 1956, must be determined not by the use for which a particular purchaser buys it but with reference to the general property which makes it saleable to the entire range of prospective buyers. In that case sodium silicate was held falling in the category of a "chemicals of all kinds" in item No. 7 of the aforesaid notification. Similarly in Indian Ceramic House v. Commissioner of Sales Tax [1970] 26 STC 413 the view taken by this Court was that liquid gold used for decoration of glasses and ceramic articles is taxable as a chemical and not as bullion or as an unspecified item. Calcium carbide was held taxable as chemical in Industrial Chemical Corporation v. Commissioner of Sales Tax [1972] 30 STC 172. Similarly tinopal was held to be a chemical in Harnarain Purshottam Das v. Commissioner of Sales Tax [1971] 28 STC 77, but there is a notable observation made in that case by Gulati, J. It was the entry "chemicals of all kinds" in Notification No. 905/X dated 31st March, 1956, which was for consideration and the view taken by Pathak, J., was that a chemical may also be used as washing material and the mere circumstance that it is possible to distinguish tinopal as washing material cannot take it out of the category of chemicals of all kinds. Gulati., J. was of the opinion that the fact that whitening brought about by tinopal is a chemical process is of no consequence because that is not the criterion upon which the entries in the notifications under the U.P. Sales Tax Act are to be interpreted. If an article falls in a specific classification of washing materials, it would cease to belong to the general category of chemicals. Since in the assessment years 1958-59 and 1959-60 there was no separate classification of washing material, it was held, that tinopal would be covered by the entry "chemicals of all kinds". THIS supports the view which I have taken above that since this commodity falls in a specific classification of "medicines" which was there in the year under consideration, it would cease to belong to the general category of chemicals and thus even if the dictionary meaning given to this commodity is accepted, it would not make any difference. A chemical when sold as a medicine and used for medicinal purposes will qualify for the lower rate of tax : see Industrial Gases Ltd. v. Commissioner of Sales Tax [1968] 21 STC 124 at 126. In that case the assessee manufactured oxygen gas and sold the same both for industrial and medicinal purposes. It was held that when sold for industrial purposes it would be taxed under Notification No. ST-905/X dated 31st March, 1956, as chemical and when sold for medicinal purposes it would be taxed under Notification No. ST-3504/X dated 10th May, 1956, as a medicine. In B. Shah and Company v. State of Gujarat [1971] 28 STC 5, after considering the qualities and attributes, character and composition and recommended or intended uses as advertised by the manufacturers, it was held that Nycil medicated powder is a medicine and not a toilet article. "Jari booti" was held as medicine because these herbs are sold primarily for their medicinal qualities, in Commissioner of Sales Tax v. Gramodyog Karyalaya [1979] 44 STC 270; 1979 UPTC 884, and similarly in Commissioner of Sales Tax v. Murari Brothers reported at page 1091 in the same volume (1979 UPTC); [1980] 46 STC 88 bhimseni kajal was treated as Ayurvedic medicine and not as a cosmetic or a toilet article. It would thus be seen that in these cases the meaning attributed to the articles concerned was not what is construed in the scientific or technical sense but was as understood in common parlance and by persons dealing with the same and that is the cardinal principle of interpretation in this behalf : see Porritts and Spencer (Asia) Ltd. v. State of Haryana [1978] 42 STC 433 (SC); 1979 UPTC 866 (SC) in which dryer felts made out of cotton or woollen yarn were held to be textiles. To conclude, therefore, in my opinion tartaric acid has been rightly treated as a medicine by the appellate and the revising authorities. The revision hence fails and is dismissed with costs to the respondent-assessee, which are assessed at Rs. 200.;