Ordinary meaning of "sealed containers" in tax exemptions extends to securely closed confectionery packets, not just tins.

Words in a tax exemption notification are to be given their ordinary popular meaning unless the context requires otherwise. On that approach, confectionery packed in securely closed cardboard packets or cellophane coverings is treated as sold in "sealed containers" if the contents cannot be reached without breaking the fastening. The construction does not limit the term to tins or wax-impressed seals, and the exemption was therefore unavailable on the facts stated, leaving the turnover taxable.

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Issues: Whether confectionery packed in cardboard packets, cellophane coverings, or similar coverings, which must be torn or broken to reach the contents, is sold in "sealed containers" within the meaning of the exemption notification under the U.P. Sales Tax Act, 1948.

Analysis: The decisive question was the meaning of "sealed containers" in the exemption notification issued under section 4 of the U.P. Sales Tax Act, 1948. The Court rejected a narrow construction confined to tins or to wax-impressed seals and held that the expression must be understood in its ordinary popular sense. A container is sealed if it is so closed that access to the contents is not possible without breaking the fastening. On that construction, securely closed cardboard packets or covered confectionery packets fall within the expression, and the notification does not warrant a distinction between sealed tins and sealed cardboxes.

Conclusion: Confectionery sold in securely closed packets of the kind in question is sold in sealed containers, and the exemption claimed by the assessee is not available.

Final Conclusion: The statutory exemption was construed according to the ordinary meaning of the expression used, and the turnover of confectionery sold in the disputed packets remained taxable.

Ratio Decidendi: Words in a tax exemption notification must be given their ordinary popular meaning unless the context requires otherwise, and a container is "sealed" if it cannot be opened without breaking the fastening.

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