Commercial meaning of "atta" includes besan under the sales tax notification, securing concessional treatment for the assessee.

The term "atta" in the U.P. Sales Tax Act notification was construed in its ordinary and commercial sense, and on that basis besan, being fine gram flour, was held to fall within its scope. The notification exempted atta, maida and suji from tax except at specified points of sale, so including besan within "atta" meant it was treated according to the notification's concessional treatment. The issue was answered in favour of the assessee and against the Sales Tax Commissioner.

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Issues: Whether besan is covered by the expression "atta" in the notification issued under section 3-A of the U.P. Sales Tax Act, 1948, and is therefore taxable in the manner provided therein.

Analysis: The notification exempted atta, maida and suji from tax except at specified points of sale. The decisive question was whether besan, being fine gram flour, could be treated as falling within the ordinary and commercial meaning of "atta" used in the notification. On that construction, the expression was held broad enough to comprehend besan.

Conclusion: Besan is included in "atta" for the purpose of the notification, and the question was answered in the negative, in favour of the assessee and against the Commissioner, Sales Tax.

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