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Issues: Whether blended coffee powder sold as French coffee fell within the expression "coffee" in section 5(v) of the Madras General Sales Tax Act so as to attract the higher single-point rate of tax.
Analysis: The expression "coffee" in the taxing entry was construed in its ordinary and commercial sense. The later enactment of 1959, which separately described coffee, chicory, and French coffee, was treated as a relevant aid to understanding the legislative understanding of the commodity. The later scheme showed that pure coffee and coffee mixed with chicory were treated as distinct items, and that chicory itself had been separately brought into the single-point levy only thereafter. On that basis, the expression "coffee" in section 5(v) was held not to extend to coffee blended with chicory.
Conclusion: Blended coffee powder was not "coffee" within section 5(v), and the assessment at the ordinary rate was correct.
Final Conclusion: The revision petition failed, and the assessment adopted by the Tribunal was sustained.
Ratio Decidendi: In construing a taxing entry, the commodity must be understood according to its ordinary and commercial meaning, and a later statutory classification of distinct varieties may be used as an interpretive aid where it reflects the legislative conception of the commodity.