Binding larger-Bench precedent upheld purchase tax on sugarcane purchases, rejecting displacement by the special sugarcane regulation law.

A larger-Bench precedent on the Punjab General Sales Tax Act, 1948 was treated as binding on the question whether purchase tax on sugarcane bought by sugar mills was leviable notwithstanding the Punjab Sugarcane (Regulation of Purchase and Supply) Act, 1953. The Court applied Jagatjit Sugar Mills and held that purchase tax was payable under section 4(1) of the 1948 Act, while distinguishing Gobind Sugar Mills because it arose under a different statutory framework. The special regulatory regime did not displace the general taxing provision, so the challenge to the levy under the 1948 Act failed and the petitions were dismissed.

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Issues: Whether purchase tax on sugarcane purchased by sugar mills was exigible under the Punjab General Sales Tax Act, 1948 despite the Punjab Sugarcane (Regulation of Purchase and Supply) Act, 1953 and whether the levy under the Punjab Value Added Tax Act, 2005 could be avoided on the same basis.

Analysis: The controlling question was whether the special regime under the 1953 Act displaced the general taxing provisions of the Punjab General Sales Tax Act, 1948. The Court held that the issue was already concluded by the larger Bench decision in Jagatjit Sugar Mills, which had categorically ruled that purchase tax was leviable under section 4(1) of the Punjab General Sales Tax Act, 1948 on purchases of sugarcane by sugar mills. The Court distinguished Gobind Sugar Mills on the ground that it arose under a different statutory framework and could not override the binding effect of the earlier three-Judge Bench decision interpreting the very Act applicable to the petitioners. On that basis, the challenge to levy under the 1948 Act could not succeed, and the Court did not separately examine other contentions.

Conclusion: The purchase tax was held payable under the Punjab General Sales Tax Act, 1948, and the plea that the 1953 Act alone governed the field was rejected.

Final Conclusion: The writ petitions were dismissed because the prior larger-Bench declaration on the applicable taxing provision bound the Court and sustained the impugned levy.

Ratio Decidendi: A larger-Bench decision directly interpreting the statute in question binds subsequent courts, and a special regulatory enactment does not displace the general taxing provision where the controlling precedent has already upheld the levy under that general law.

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