Common parlance interpretation brings aloe vera juice within processed or preserved vegetables, excluding unclassified taxation.

Aloe vera juice was treated as falling within the wide amplitude of the expression "processed or preserved vegetables" in Entry 103 of Schedule-II of the Uttar Pradesh Value Added Tax Act, 2008, because aloe vera is marketed in processed forms such as juice and jelly and comparable products have been covered by similar entries in other States. The common parlance test was applied, so the term was understood as traders and consumers would understand it. The Revenue's long-standing practice of taxing aloe vera juice at the lower applicable rate also supported continuity, and no material change justified departure. Aloe vera juice was therefore not liable to tax as an unclassified item.

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Issues: Whether aloe vera juice is covered by the expression "processed or preserved vegetables" under Entry 103 of Schedule-II of the Uttar Pradesh Value Added Tax Act, 2008, or is liable to be taxed as an unclassified item.

Analysis: The expression in Entry 103 was held to be of wide amplitude. The Court noted that aloe vera is marketed in processed forms such as juice and jelly, and that the taxing authorities in other States had treated such products as covered by comparable entries. It also applied the settled principle that tariff entries are to be understood in common parlance and in the sense in which traders and consumers understand them. The Court further relied on the consistency of past assessment practice, observing that the Revenue had taxed aloe vera juice at the lower applicable rate for several years and could not depart from that position without material change.

Conclusion: Aloe vera juice falls within the expression "processed or preserved vegetables" under Entry 103 and is not an unclassified item. The question of law was answered in favour of the dealer and against the Revenue.

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