Specific exclusion from sugar exemption brought batasha and illaichidana within sales tax liability.

The exemption for sugar under the U.P. Sales Tax Act, 1948 was later narrowed by a notification expressly excluding batasha and illaichidana from its scope. A subsequent notification under section 3-A separately brought such sugar products to tax in the hands of the manufacturer or importer. The dealer's claim to exemption failed because the general sugar exemption could not override the later specific exclusion, and the earlier authorities had extended the exemption beyond its text. The dealer's cited precedents were distinguished since they did not concern an express exclusion of these goods. Batasha and illaichidana manufactured by the dealer were therefore liable to sales tax.

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Issues: Whether batasha and illaichidana manufactured by the dealer were exempt from sales tax under the exemption notification for sugar, or whether the later notifications specifically excluding such sugar products rendered the turnover taxable.

Analysis: The exemption originally granted to sugar under the notification issued under section 4 of the U. P. Sales Tax Act, 1948 was later modified by the notification dated 1 December 1969, which expressly excluded sugar products such as batasha and illaichidana from the exemption. A further notification issued under section 3-A of the Act separately made such products liable to tax in the hands of the manufacturer or importer. The earlier authorities treating these goods as exempt proceeded on an erroneous extension of the general exemption to commodities specifically excluded by the later notifications. The precedents relied upon by the dealer were distinguished because they did not involve a notification containing an express exclusion of batasha and illaichidana from exemption.

Conclusion: Batasha and illaichidana manufactured by the dealer were liable to sales tax and were not entitled to exemption under the earlier notification.

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