Broad meaning of sugar extends tax exemption to sugar-candy under the exemption entry.

Sugar includes all forms of the commodity regardless of shape, texture, colour, density or name, so sugar-candy was treated as falling within the exempted article. Because sugar was already a tax-free item under the exemption entry, sugar-candy inherited the same exemption. The contrary view of the Delhi High Court was not followed in light of the binding Supreme Court interpretation, and the issue was answered against the Revenue and in favour of the assessee.

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Issues: Whether sugar-candy (misri) falls within the meaning of sugar and, as such, qualifies as a tax-free article under the relevant exemption entry.

Analysis: The Court applied the authoritative interpretation that the term "sugar" includes all forms of sugar, irrespective of shape, texture, colour, density, or name. On that basis, sugar-candy was treated as a form of sugar. Since sugar was admittedly a tax-free article under the exemption list, sugar-candy, being included within sugar, inherited the same exemption. The contrary view of the Delhi High Court was not preferred in view of the binding decision of the Supreme Court.

Conclusion: Sugar-candy is included within sugar and is therefore a tax-free article; the question was answered against the Revenue and in favour of the assessee.

Ratio Decidendi: A commodity falling within the broad and inclusive meaning of an exempted article is entitled to the same exemption, even if it is sold under a different name or in a different form.

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