Sales tax exemption for raw food items does not extend to cooked preparations made from them.

Vegetables, fish, meat and eggs were exempt from sales tax only in their raw condition under the Punjab General Sales Tax Act, because exemption entries in Schedule B must be confined to the goods expressly covered. The court treated cooked preparations such as curry and other food dishes as distinct taxable commodities, noting that later entries for Indian food preparations indicated a separate legislative treatment. The exemption therefore did not extend to cooked products made from the listed raw ingredients, and the Revenue's view was upheld.

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Issues: Whether vegetables, fish, meat and eggs sold as consumption articles were exempt from sales tax only in their raw form, or whether the exemption extended to cooked preparations made from them.

Analysis: Section 6 of the Punjab General Sales Tax Act, 1948 exempted only those goods specified in Schedule B, while the charging provision in section 5 made sales tax generally leviable on taxable turnover. Entries 16 and 18 in Schedule B referred to vegetables, meat, fish and eggs, subject to the stated conditions. The later insertion of entries relating to Indian food preparations and other eatables showed that cooked dishes and food preparations were treated as different articles from the raw ingredients from which they were made. The use of the listed items in ordinary trade also pointed to their raw and uncooked condition, while cooked items such as vegetable curry, meat curry and fish curry were separate taxable preparations.

Conclusion: The exemption applied only to vegetables, meat, fish and eggs in their raw condition and did not extend to cooked preparations made from them; the answer was in favour of the Revenue.

Final Conclusion: The reference was answered in the affirmative against the assessee, and the sales tax authorities' view was upheld.

Ratio Decidendi: Exemption entries in a sales tax schedule must be confined to the goods expressly covered by them, and cooked food preparations are distinct taxable commodities from their raw ingredients unless specifically exempted.

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