Edible oil classification: Ambada oil was upheld as edible oil for tax purposes, and the revision failed.

Ambada oil was treated as an edible oil for tax classification under Entry No. 128 because the revisional authority's contrary view was unsupported by material. The Tribunal's reliance on the Commissioner, Sales Tax clarification and the Director of Industries' opinion was accepted as supporting the edible-oil classification. In the absence of evidence to sustain the revisional authority's finding, the Tribunal's conclusion was held free from illegality and the tax revision failed.

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Issues: Whether Ambada oil was an edible oil liable to tax at the rate applicable to edible oils under Entry No. 128, and whether the Tribunal's finding in favour of the assessee could be sustained.

Analysis: The revisional authority's view that Ambada oil was not an edible oil was held to be unsupported by material. The Tribunal had relied on the clarification of the Commissioner, Sales Tax, and the opinion of the Director of Industries, both of which supported the classification of Ambada oil as an edible oil. In the absence of evidence sustaining the revisional authority's contrary conclusion, the Tribunal's order was found to be free from illegality.

Conclusion: The finding that Ambada oil is an edible oil was upheld, and the tax revision was dismissed.

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