Concessional sales tax notification confined to expressly named oils and cannot extend to solvent-extracted oil from oil-cakes.

A concessional sales tax notification for oils produced from specified oilseeds could not be extended to oil extracted from oil-cakes by solvent process, because oil-cakes were a separate raw material and the resulting product was not the same as oil directly produced from sarson, toria, til or taramira. The fiscal concession had to be confined to commodities expressly covered by the notification, and could not be enlarged by implication to a distinct product not specifically included.

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Issues: Whether oil extracted from oil-cakes by using solvent was covered by the notification granting concessional sales tax on oils produced from sarson, toria, til and taramira.

Analysis: The notification applied to oils produced from the specified oilseeds and did not mention oil-cakes. Oil-cakes were treated as a separate raw material, and oil extracted from them by solvent process was not the same as oil straightway produced from sarson or the other enumerated seeds. The concession could not be extended by implication to a commodity not expressly covered by the notification.

Conclusion: The concessional notification did not cover oil produced from oil-cakes by solvent extraction, and the challenge failed.

Ratio Decidendi: A fiscal notification granting a concessional rate must be confined to the commodities expressly covered by its language and cannot be extended to a distinct product not specifically included.

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