Fuel used only in food preparation is not taxable as manufacturing input under the Kerala sales tax provision.

Firewood and charcoal used only as fuel in preparing meals were treated as inputs that merely aided the cooking process, not as raw material or ingredients in the manufacture of goods for sale. On that reasoning, turnover from those goods did not attract tax under section 5A(1)(a) of the Kerala General Sales Tax Act. The stated principle is that goods used only as fuel or as an aid in manufacture, and not as raw material in the finished product, fall outside that taxing provision.

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Issues: Whether the turnover of firewood and charcoal used as fuel in preparing meals in the hotel was liable to tax under section 5A(1)(a) of the Kerala General Sales Tax Act.

Analysis: The firewood and charcoal were used only as fuel for preparation of food. There was no material to show that they were used as raw material in the manufacture of goods for sale. Goods used merely as an aid in the process of manufacture, and not as ingredients or raw material of the finished product, do not attract tax under section 5A(1)(a).

Conclusion: The turnover relating to firewood and charcoal was not taxable under section 5A(1)(a) of the Kerala General Sales Tax Act, and the revision failed.

Ratio Decidendi: Goods used only as fuel or as an aid in manufacture, and not as raw material in the manufacture of goods for sale, are not taxable under section 5A(1)(a) of the Kerala General Sales Tax Act.

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