Interpretation of "karyana" in tax law includes gur, shakkar and sugar where the term is left undefined.

The expression "karyana" was interpreted as provisions in common use, equivalent to groceries, and was held broad enough to include gur, shakkar and sugar for sales tax assessment and registration. Because the departmental term was not clearly defined, the court noted that vague taxation language should not be left to administrative guesswork and that ambiguity must be resolved in favour of the subject. On that construction, gur, shakkar and sugar fell within "karyana", and the revision petition was accepted.

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Issues: Whether the expression "karyana" included gur, shakkar and sugar for purposes of sales tax assessment and registration.

Analysis: The expression "karyana" was treated as meaning provisions in common use, equivalent to groceries, and therefore capable of including commodities such as sugar, shakkar and gur. The absence of a clear departmental definition created uncertainty and allowed different assessing authorities to apply the term differently. In taxation matters, undefined or vague terms should not be left to administrative guesswork, and the subject is entitled to the benefit of interpretation where the expression used by the Department is not precise.

Conclusion: Gur, shakkar and sugar were held to fall within the category of "karyana", and the revision petition was accepted.

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