Vermicelli classification under sales tax law turns on ordinary meaning of food and ingredient use.

Vermicelli sold as "Bambino vermicelli" was treated as an ingredient used in preparing dishes, not as food ordinarily eaten straightaway. On that ordinary meaning test, it did not fall within "articles of processed food" under entry 129A of the Andhra Pradesh General Sales Tax Act, 1957. The product was therefore taxable only as maida under entry 60. The Court found it unnecessary to examine the alternative argument on processing, because the classification turned on whether vermicelli was food in its ordinary sense.

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Issues: Whether vermicelli manufactured and sold under the trade name "Bambino vermicelli" falls within entry 129A of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 as "articles of processed food", or is taxable only as maida under entry 60.

Analysis: The decisive question was whether vermicelli can be regarded as "food" within the ordinary sense of something readily eaten. The Court noted that the product is not ordinarily consumed straightaway, but is used as an ingredient in preparing other dishes such as sweets, upma, pakoda, and similar preparations. On that basis, it treated vermicelli as an ingredient in food rather than food itself. Since this conclusion disposed of the matter, it was unnecessary to examine whether the product had undergone processing in the sense urged by the petitioner.

Conclusion: Vermicelli sold as "Bambino vermicelli" does not fall under entry 129A and cannot be taxed as processed food; it is taxable only as maida under entry 60.

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