Mother liquor from khandasari sugar manufacture qualifies as molasses and remains taxable despite trade description differences.

Mother liquor produced in the final stage of khandasari sugar manufacture by the open pan process was treated as molasses for sales tax purposes. Because the sales tax statute did not define "molasses," the court looked to dictionary meaning and the Molasses Control Order, 1961, which treated such residue as molasses and extended the Order to it. The substance's character was not changed by being described as liquid jaggery or by differences in price, appearance, use, or trade description. It was therefore taxable under the sales tax entry applied by the authorities.

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Issues: Whether the mother liquor or liquid jaggery known as patla gur, produced in the course of manufacture of khandasari sugar by the open pan process, is liable to be taxed as molasses.

Analysis: The word "molasses" was not defined in the sales tax statute, so its meaning was gathered from dictionaries and from the Molasses Control Order, 1961. The Order treated mother liquor produced in the final stage of manufacture of khandasari sugar by the open pan process as molasses, and clause 11 extended the Order to such molasses. The Court also held that the substance remained a liquid or semi-liquid residue obtained in sugar manufacture, and that differences in name, price, appearance, or use did not alter its basic character. The monograph relied on by the assessee did not displace this conclusion.

Conclusion: The substance is molasses and is taxable accordingly under the sales tax entry applied by the authorities.

Ratio Decidendi: Where a substance remains the mother liquor produced in the final stage of manufacture of khandasari sugar, its basic character as molasses is not altered by being described as liquid jaggery or by differences in price, use, or trade description.

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