Ordinary commercial meaning of "cooked food" excludes biscuits under sales tax notifications, leaving them unclassified.

In construing sales tax notifications, the relevant meaning of "cooked food" is the sense ordinarily understood in the local market and by users of the language in the area of operation. Applying that commercial and popular meaning, biscuits were held not to fall within "cooked food", even though they involve baking and may be described more broadly as prepared food. The contemporaneous Hindi expression and the context of the notifications supported the narrower ordinary meaning, so biscuits were treated as an unclassified commodity rather than covered by the cooked food entry.

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Issues: Whether biscuits fall within the expression "cooked food" used in the sales tax notifications issued under the U.P. Sales Tax Act, 1948.

Analysis: In construing a tax notification, the relevant meaning is the sense in which the expression is ordinarily understood in the local market or by persons using the language in the area of operation. Although biscuit may involve baking and may in a wider sense be described as prepared food, it is not ordinarily understood as cooked food. The contemporaneous Hindi expression also indicated the same commercial and popular understanding, and the context of the notification did not support an extended meaning that would include biscuits.

Conclusion: Biscuits do not fall within the expression "cooked food" in the notifications, and the classification of biscuits as an unclassified commodity was .

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