Cotton seed oil tax classification remains fact-dependent, and a binding precedent barred renewed writ challenge.

Cotton seed oil was treated as eligible for concessional tax only if, on the facts, it qualified as edible oil; the question depended on the nature of the oil sold and the dealer's infrastructure for making it edible. The High Court noted that the issue had already been decided by an earlier binding Division Bench ruling and could not be reopened in writ proceedings on the same controversy. In the absence of any contrary authority, the connected petitions were disposed of in accordance with that precedent, leaving the assessment and demand undisturbed.

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Issues: Whether cotton seed oil was entitled to be treated as edible oil for the concessional rate of tax and whether the connected petitions could be interfered with in writ jurisdiction in view of the earlier Division Bench decision.

Analysis: The petitions challenged assessment and reopening proceedings on the footing that cotton seed oil was edible oil and therefore taxable at the concessional rate notified for edible oils. The controversy had already been decided by the earlier Letters Patent Bench, which held that whether cotton seed oil was edible oil depended on facts such as the nature of the oil sold and the dealer's infrastructure for making it edible, and that the issue could not be freshly re-agitated in writ proceedings. The Court found that the present cases were covered by that binding decision and that no contrary authority had been shown.

Conclusion: The petitions were governed by the earlier binding decision and no interference was warranted; the challenge failed.

Final Conclusion: The connected petitions stood disposed of in accordance with the earlier Division Bench ruling, leaving the tax assessment and demand undisturbed.

Ratio Decidendi: Whether cotton seed oil is edible oil for concessional sales tax treatment is a fact-dependent question, and once a binding precedent has determined the issue, a later writ petition raising the same controversy is to be disposed of in line with that precedent.

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