Raw material for manufacturing set-off includes natural gas used in M.S. ingot production under trade tax law.

Natural gas used in the manufacture of M.S. ingot was treated as raw material for set-off under Section 4-BB of the U.P. Trade Tax Act, 1948, because the provision extends relief on tax paid on raw material and packaging material used in manufacture. The court applied a strict interpretative approach, holding that taxing provisions must be read as written without adding or deleting words. It also noted that analogous treatment under Section 4-B(2) supported inclusion of input used in the manufacturing process within the expression raw material. The rejection of the dealer's set-off claim was therefore unsustainable.

---

---

Issues: Whether natural gas used in the manufacture of M.S. Ingot constituted raw material so as to entitle the dealer to set off under Section 4-BB of the U.P. Trade Tax Act, 1948.

Analysis: The dispute turned on the scope of the expression raw material in Section 4-BB, which grants set off on tax paid on raw material and packaging material used by a manufacturer. The Court noted that the manufacture of M.S. Ingot involved the use of natural gas as fuel in the process, and relied on the interpretative approach adopted in earlier decisions that taxing provisions must be read as they are, without adding or deleting words. It also held that the benefit extended in analogous cases under Section 4-B(2) supported the view that input used in the manufacturing process can fall within the expression raw material for the purposes of set off.

Conclusion: Natural gas used in manufacturing M.S. Ingot was held to be raw material for the purposes of Section 4-BB, and the rejection of the set off claim was found unsustainable.

---