Edible oil classification and revisional reopening depend on statutory context, processing standards, and jurisdictional limits.

Washed cotton-seed oil was treated as edible oil for sales tax purposes because, where the taxing statutes gave no definition, edibility had to be determined from the governing regulatory and commercial context, including food standards and control orders; the product was found to be oil fit for human consumption after processing, and no further refinery plant requirement was established. Reopening of completed assessments under section 21(1) of the Punjab General Sales Tax Act, 1948 was also described as permissible only where the subordinate order shows illegality or impropriety; a merely different possible view on the material was insufficient. The revisional power was therefore not to be used to reopen completed assessments without jurisdictional basis.

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Issues: (i) Whether washed cotton-seed oil sold by the assessee was edible oil for purposes of sales tax assessment; (ii) Whether suo motu reopening of the completed assessments under section 21(1) of the Punjab General Sales Tax Act, 1948 was justified.

Issue (i): Whether washed cotton-seed oil sold by the assessee was edible oil for purposes of sales tax assessment.

Analysis: The expression "edible oil" was not defined in the taxing enactments. The Court therefore examined the prevailing statutory and administrative descriptions, including the Control Order under the Essential Commodities Act, 1955, the Government of India instructions under the Agricultural Produce (Grading and Marking) Act, 1937, and the standards in the Prevention of Food Adulteration Rules, 1955. The material showed that washed cotton-seed oil was treated as oil used for human consumption after processing, and the assessee's product was found to be washed cotton-seed oil. The insistence on a further refinery plant as a precondition for edibility was unsupported by any governing requirement.

Conclusion: The washed cotton-seed oil sold by the assessee was edible oil, and the higher rate applied on the premise of non-edibility was not sustainable.

Issue (ii): Whether suo motu reopening of the completed assessments under section 21(1) of the Punjab General Sales Tax Act, 1948 was justified.

Analysis: Section 21(1) permits revision only to satisfy the authority as to the legality or propriety of a subordinate order. The original assessments had adopted one possible view on the material before the assessing authority and disclosed no concealment, patent illegality, or impropriety. Reopening years later, when relevant evidence may no longer be available, was unwarranted. The existence of an alternative remedy did not bar interference where the notices themselves were unsupported by jurisdictional basis.

Conclusion: The suo motu reopening was not justified, and the impugned notices and revisional orders could not stand.

Final Conclusion: The assessee succeeded in challenge to the reassessment notices and revisional orders, and the assessments could not be reopened on the facts found.

Ratio Decidendi: In the absence of a statutory definition, edibility of oil must be determined from the governing legal and commercial context, and revisional power cannot be used to reopen a completed assessment unless the subordinate order is shown to suffer from illegality or impropriety.

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