Ordinary meaning of "vegetables" in sales tax law excludes betel leaf from exemption under the Bengal Finance Act.

Betel leaf was held not to fall within the ordinary meaning of "vegetables" in item 6 of the Bengal Finance (Sales Tax) Act Schedule, so it was not exempt from tax on that basis. The Court construed the exemption entry "Vegetables, green or dried" in the context of the surrounding foodstuff entries and preferred the common and popular meaning of "vegetables" over a broad botanical meaning. It also followed the consistent view of other High Courts that betel leaf is not ordinarily treated as a foodstuff or vegetable in taxing statutes, and declined to give the later explanatory amendment a wider meaning for the period in question.

---

---

Issues: Whether betel leaf or pan is a "vegetable" within item 6 of the Schedule to the Bengal Finance (Sales Tax) Act and therefore exempt from tax.

Analysis: The exemption entry "Vegetables, green or dried" was construed in the setting of the surrounding schedule entries, all of which related to foodstuffs. The Court preferred the ordinary and commonly understood sense of "vegetables" rather than the widest botanical sense. It relied on the consistent approach of other High Courts, which had held that betel leaf is not a food-stuff and does not ordinarily fall within the term "vegetable" in taxing enactments. The subsequent amendment explaining the entry did not persuade the Court to adopt a broader meaning for the period in question.

Conclusion: Betel leaf is not a vegetable within item 6 of the Schedule to the Bengal Finance (Sales Tax) Act and is not exempt on that ground.

---