Purposive reading of 'goods' under the Central Sales Tax Act allowed newsprint and related materials in registration.

The exclusion of newspapers from the taxability definition of "goods" under the Central Sales Tax Act was treated as context-specific and not as a blanket denial of their commercial character. Sections 7 and 8 were read purposively to permit concessional inter-State purchases of goods intended for resale or for use in manufacture for sale. On that approach, newsprint was held to qualify as merchandise used in newspaper production, and ancillary materials needed for the business could also be included in the registration certificate. The presence of waste paper as a by-product did not alter the conclusion, because the dealer's real business remained newspaper manufacture and sale.

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Issues: Whether newsprint and other materials used in the manufacture of newspapers could be included in the certificate of registration under the Central Sales Tax Act, notwithstanding the exclusion of newspapers from the definition of "goods" for taxability purposes.

Analysis: Newspapers had historically been treated as goods and were taken out of the tax net only to prevent their sale from being taxed. The exclusion in the definition of "goods" was read as a context-specific restriction aimed at taxability, not as a complete denial of the commercial character of newspapers or newsprint for all purposes under the Act. Sections 7 and 8 were construed in the light of their object, namely, to enable a registered dealer to obtain concessional inter-State purchases of goods intended for resale or for use in the manufacture of goods for sale. Applying that context, the definition in section 2(d) was not treated as controlling where the statutory purpose required a wider meaning. Newsprint was held to be ordinary merchandise used in the manufacture of newspapers and thus eligible for inclusion, along with ancillary materials required for the business. The court also accepted that inclusion of waste paper as a by-product did not justify exclusion of newsprint, since the dealer's real business was the manufacture and sale of newspapers.

Conclusion: The petitioner was entitled to have newsprint and other necessary materials included in the certificate of registration under sections 7 and 8 of the Central Sales Tax Act, 1956.

Ratio Decidendi: A statutory definition excluding an item from taxability does not, by itself, prevent that item from being treated as goods for a different provision when the context and object of the statute require a broader meaning.

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