Binding Supreme Court precedent on purchase tax on sugarcane controlled the issue, defeating attempts to distinguish it.

A High Court must follow a Supreme Court ruling directly construing the same taxing provisions and cannot depart from it because an additional argument was not considered earlier or because another decision concerned different enactments. Applying that binding precedent, the court held that purchase tax on sugarcane was leviable under Section 4(1) of the Punjab General Sales Tax Act, 1948, and that Section 4-B did not govern Schedule B goods. The challenge based on the Punjab Sugarcane (Regulation of Purchase & Supply) Act, 1953 and Article 266 failed, and the taxpayer remained liable to pay purchase tax.

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Issues: Whether the appellant was liable to pay purchase tax on sugarcane under the Punjab General Sales Tax Act, 1948 notwithstanding the Punjab Sugarcane (Regulation of Purchase & Supply) Act, 1953, and whether the High Court could depart from the Supreme Court's prior ruling on the same provisions.

Analysis: The questions turned on the binding force of the Supreme Court's decision construing the same taxing provisions. The earlier decision held that purchase tax on sugarcane was levied under Section 4(1) of the Punjab General Sales Tax Act, 1948, and that Section 4-B did not govern Schedule B goods. The Court rejected the attempt to distinguish that ruling on the basis of the Punjab Sugarcane Act, 1953 and the later decision in Gobind Sugar Mills, noting that the latter concerned different enactments and that a High Court cannot disregard a direct Supreme Court decision merely because a further argument was not considered there. The contention based on Article 266 was also rejected as incapable of displacing the binding precedent.

Conclusion: The appellant remained liable to pay purchase tax on sugarcane under the Punjab General Sales Tax Act, 1948, and the challenge to the contrary failed.

Ratio Decidendi: A High Court must follow a Supreme Court decision directly construing the same statutory provisions, and cannot depart from it on the ground that an additional argument or a different decision concerning other enactments was not considered there.

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