Tax classification of soda in bar-attached hotels turns on specific entries, not a broad reading of beverages.

Soda sold or served in bar-attached hotels was held to fall under the specific Kerala General Sales Tax Act entries for aerated waters and soda, not under the broader entries for cooked food and beverages. The court applied the plain and contextual meaning rule for taxing entries and rejected an expanded reading of "beverages" to include soda. It treated soda as an aerated water rather than a beverage ejusdem generis with cooked food, so the specific classification governed and the assessees obtained no relief.

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Issues: Whether soda sold or served in bar-attached hotels is taxable under the entry for cooked food and beverages or under the entry for aerated waters and soda in the Kerala General Sales Tax Act, 1963.

Analysis: The relevant entries changed across the assessment years, but the interpretive question remained whether the expression "beverages" in the cooked food entries could be expanded to include soda. Applying the settled rule that taxing entries must be construed on their plain language, and reading the term in its context, the Court held that "beverages" in entries 40 and 46 is controlled by the preceding words "cooked food". Soda, though a beverage in a broad sense, is an aerated water and not a beverage ejusdem generis with cooked food. The specific entries for aerated waters and soda therefore govern the tax treatment, and the broader cooked food entries do not cover soda sold in bar-attached hotels.

Conclusion: Soda sold or served in bar-attached hotels is not covered by entries 40 or 46 and remains taxable under the specific entries relating to aerated waters and soda. The revisions fail and the assessees do not obtain relief.

Final Conclusion: The dispute on classification of soda under the KGST Act was resolved against the assessees, and the tax revisions were dismissed.

Ratio Decidendi: In taxing statutes, a specific entry prevails over a general expression only when the language and context support that classification, and a term used in a taxing entry must be given its plain and contextual meaning without expanding it beyond its natural scope.

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