Milk product exemption covers ice-cream under a broad sales tax notification interpretation.

The term "milk products" in the U.P. Sales Tax exemption notification was construed by its ordinary language and commercial understanding because neither the Act nor the Rules defined it. The broad wording, including the illustrative phrase "such as," showed an intention to cover products beyond the named examples, while the exclusion of sweetmeats sold in sealed containers supported a wider reading of milk-based goods. On that basis, ice-cream, being made from milk, cream and milk solids, was treated as a milk product and therefore fell within the exemption from sales tax.

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Issues: Whether ice-cream is a "milk product" within the exemption notification issued under the U. P. Sales Tax Act and therefore exempt from sales tax.

Analysis: The expression "milk products" was not defined in the Act or the Rules, so the entry had to be construed according to its language and commercial understanding. The notification used broad wording and the phrase "such as" was illustrative, showing an intention to extend exemption beyond the named examples. The exclusion of sweetmeats sold in sealed containers also indicated that the notification covered products prepared from milk as well as those produced out of milk. Since ice-cream is made from milk and milk products and its basic ingredients are milk, cream and milk solids, it falls within the scope of the exempted entry.

Conclusion: Ice-cream is a milk product and is exempt from sales tax under the notification.

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