Tax exemption for water excludes sterilised distilled water used for injections, leaving the product taxable.

Sterilised distilled water used for injection does not qualify as exempt "water" under section 4 of the U.P. Sales Tax Act where the exemption expressly excludes distilled water. On the material described, water for injection was treated as distilled water intended for parenteral administration and sterile products, so it fell within the statutory exclusion rather than the general exemption. The assessee was therefore not entitled to exemption on the turnover of water for injection, and the assessment challenge failed.

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Issues: Whether water for injection is exempt from tax as "water" under section 4 of the U.P. Sales Tax Act.

Analysis: The exemption provision excluded only specified kinds of water from tax, including distilled water. On the material before the Court, water for injection was sterilised distilled water intended for parenteral administration and other sterile products. It therefore fell within the expression "distilled water" in the exclusionary explanation to section 4, and not within exempt "water" simpliciter.

Conclusion: Water for injection is not exempt from tax as ordinary water under section 4 and is covered by the exclusion for distilled water. The revision failed on this issue and the view of the revising authority was upheld.

Final Conclusion: The assessee was not entitled to exemption on the turnover of water for injection under the statutory exemption, and the challenge to the assessment was rejected.

Ratio Decidendi: Where a tax exemption for "water" expressly excludes distilled water, sterilised distilled water used as water for injection falls within the exclusion and remains taxable.

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