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7. In Motilal Hari Prasad and bros v. State of Andhra , the question was whether the groundnut includes kernel and liable to be taxed at the purchase point. Our High Court was considering the meaning of the word "groundnut" in Rule 4(2) of the Madras General Sales Tax (Turnover and Assessment) Rules, 1939. It was held that the word "groundnut" is of wide amplitude so as to embrace within the compass the kernel also and therefore groundnut kernel is liable to be taxed at the purchase point.

8. In Tungabhadra Industries Ltd. v. Commercial Tax Officer [1960] 11 STC 827, the question before the Supreme Court was with regard to allowability of deduction of the cost of groundnut from the turnover of the hydrogenated groundnut oil known as vanaspati. The relevant rule of the Madras General Sales Tax (Turnover and Assessment) Rules, 1939, permitted such deduction from the groundnut oil. The question therefore was whether the groundnut oil and vanaspati are one and the same commodity. The Tribunal and the High Court recorded a finding that except for its keeping quality without rancidity and ease of packing and transport without leakage, hydrogenated oil serves the same purpose as a cooking medium and has identical food value as refined groundnut oil. It was further pointed out that there was no use to which the groundnut oil could be put for which the hydrogenated oil could not be used nor was there any to which the hydrogenated oil could be put for which the raw oil could not be used. The Supreme Court has observed that hydrogenated oil still continues to be "groundnut oil" notwithstanding the processing which is merely for the purpose of rendering the oil more stable thus improving its keeping qualities for those who desire to consume groundnut oil. In that view of the matter it held that the assessee was entitled to the benefit of deduction of the purchase price of the kernel or groundnut under the relevant rules. In the instant case there is no material to show that the tamarind seeds and the tamarind seed dhal are put to one and the same use and they serve the same purpose.