Statutory meaning of "petrol" under sales tax law covered dangerous petroleum products, bringing them within Schedule I taxation.

The Supreme Court of India applied the statutory meaning of "petrol" under the Kerala General Sales Tax Act, 1963 and held that special boiling point spirit and shell hexane, both admitted to be dangerous petroleum products with a flash point below 24.4 C, fell within item 57B of Schedule I. The Court held that the entry was not confined to motor fuel or substances used in combustion engines, and that the ordinary statutory meaning of the defined commodity controlled unless the context clearly required a narrower reading. The substances were therefore liable to single-point taxation under item 57B.

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Issues: Whether special boiling point spirit and shell hexane, being dangerous petroleum products with flash point below 24.4 degrees centigrade, fell within item 57B of Schedule I to the Kerala General Sales Tax Act, 1963 and were liable to single-point taxation under that entry.

Analysis: The charging scheme in section 5 distinguished goods in the Schedules from other goods liable to multi-point tax. The Act defined "petrol" as dangerous petroleum having a flash point below 24.4 degrees centigrade, and the substances in question were admitted to answer that definition. The term "petrol" in item 57B of Schedule I was to be given its ordinary statutory meaning unless the context required otherwise. The context of item 57B did not warrant excluding substances that did not serve as fuel for combustion engines, and the entry properly covered petrol other than naphtha as defined. The Court approved the High Court's ultimate conclusion that the substances fell within item 57B, though it disagreed with the High Court's reasoning on remand.

Conclusion: The substances in question were liable to tax under item 57B of Schedule I to the Kerala General Sales Tax Act, 1963.

Ratio Decidendi: Where a taxing entry uses a defined commodity term, that term must ordinarily be applied in its statutory sense, and a narrower construction will not be adopted unless the context clearly requires it.

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