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M/s. Castrol India Limited Versus Commissioner of Commercial Tax, M.P. & Others

2017 (10) TMI 426 - MADHYA PRADESH HIGH COURT

Classification of goods - levy of sales tax - Brake Fluid - The petitioner's contention is that Brake Fluid cannot be categorized as Lubricant and therefore, Sales Tax / Commercial Tax cannot be charged by treating as a Lubricant - whether the tax can be charged in respect of Brake Fluid by treating it under Entry No.9 Part-III of Schedule-II which prescribes the rate of tax in respect of description of goods as Lubricant @ 15% or tax has to be charged by treating the Brake Fluid under the resid .....

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wheel of the bicycle - With passage of time Hydraulic Brake System came into existence and the Brake Fluid was introduced. The Brake Fluid perform the same job which was being performed by the mechanical system and it transfers the force on the brake pads fixed on the brake drums (Brake Shoe). It is not at all lubricating either the brake or any part which is under the braking system. Today we have pressure brake also which exclusively work on air pressure and if the logic canvassed by the Stat .....

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and Satellite Receiver can be treated as one entry or the two item separately - The High Court has held that The functioning of “VSAT” and “Satellite receiver” is different, their actual use is different, they are differently known by the people who deal therein, and work differently. It would not be correct to treat a “VSAT” as a “satellite receiver”, so as to attract tax-ability under entry 75(i) of Notification dated January 29, 2000 issued under section 3A(1)(d) of the U. P. Trade Tax Act, 1 .....

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houdhary, learned Senior Counsel with Shri D. S. Kale, learned counsel for the petitioner. Shri Milind Phadke, learned Government Advocate for the respondent/State. ORDER As per S. C. Sharma, J:- Regard being had to the similitude in the controversy involved in the present cases, the writ petitions were analogously heard and by a common order, they are being disposed of by this Court. Facts of Writ Petition No.164/2004 are narrated hereunder. 02- The petitioner before this Court is a Company reg .....

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Deputy Commissioner of Commercial Tax and Assistant Commissioner of Commercial Tax, State of Madhya Pradesh. 03- The facts of the case reveal that the petitioner Company M/s. Castrol India Ltd. is a Company incorporated under the Companies Act, 1956. The Company was originally registered as Indrol Lubricants and Specialities Private Limited and later on the name was change to Indrol Lubricants and Specialities Limited . The name of the Company was subsequently changed as Castrol India Limited . .....

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f Tax 9. Lubricants 15% 05- The Company, as the Brake Fluid does not fall under the description of the goods i.e. Lubricant, was paying Commercial Tax under the residuary entry being Entry No.1 of Part-VII of Schedule-II which reads as under:- Entry No. Description of Goods Rate of Tax 1. All other goods not included in Schedule-I or any other part of this Schedule 15% 06- In respect of Assessment Year 1991-92, the Sales Tax Department accepted the payment of tax by treating the Brake Fluid unde .....

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nation of rates of Sales Tax in respect of Brake Fluid. 08- The application of the petitioner was not decided and the new Act came into force and the Commissioner of Commercial Tax by an order dated 07/04/1995 intimated to the petitioner that Brake Fluid falls under Entry No.7 Part-III of Schedule-II which is related to lubricants and is chargeable to Sales Tax @ 12% up to 31/03/1994 and @ 15% w.e.f. 01/04/1994. The order passed in the case of M/s. Brakes India Ltd. was followed by the responden .....

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r subsequent years also imposing tax by treating Brake Fluid as Lubricant. 10- The assessment for the period w.e.f. 01/04/1997 to 31/03/1998 was completed and an order was passed on 24/04/2001 by the Assistant Commissioner, Commercial Tax, Division No.1. An appeal was preferred by the petitioner and the appeal was decided against the petitioner by an order dated 07/03/2002. Thereafter, revision petition was preferred under Section 62(1) of the Commercial Tax Act and the same was dismissed on 21/ .....

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of the petitioner is that Brake Fluid, by no stretch of imagination, can be treated as Lubricant. 12- The respondents have filed a reply and the respondents have stated that Brake Fluid has to be treated as Lubricant and tax has rightly been charged by treating Brake Fluid as Lubricant as mentioned in the Entry No.9 Part-II of Schedule-II. The respondents have stated that functions of the Lubricant and Brake Oil are almost identical. The Lubricant reduces the friction, wear and tear in different .....

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er has rightly passed the order in exercise of power conferred under Section 42-B of M. P. General Sales Tax Act, 1958 on 21/06/1994 in the case of M/s. Brakes India Ltd. keeping in view the function and viscosity present in lubricants and Brake Fluid. 14- It has also been stated that earlier order passed by the Commissioner in matter of M/s. Brakes India Ltd. dated 21/06/1994 holds the field and the question of taking a different view by the department does not arise. Respondents have further s .....

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has been further stated that in common parlance all functional fluids are known from the word 'Lubricants' and therefore, the legislature has framed the entry for the word 'Lubricants' only. The respondents have prayed for dismissal of the writ petition. 16- Heard learned counsel for the parties as length and perused the record. 17- The basic question involved in the present case is that whether the tax can be charged in respect of Brake Fluid by treating it under Entry No.9 Part .....

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to reduce friction between surfaces in mutual contact. The Lubricant is always used for reducing friction. The basic distinction between Lubricant and Brake Fluid are as under:- i) Water Solubility: Brake Fluid is soluble in water, whereas lubricant is not soluble in water. ii) Flash Point: Universal brake fluid has flash point of 620C whereas flash point of lubricant i.e. CRB Pluc 20W/40 is 1000C. iii) Brake Fluid should not contain a trace of Lub. Oil because it affects the Rubber parts in the .....

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nder Section V, Chapter 27 of the First Schedule to the Central Excise Tariff Act which deals with Mineral fuels, mineral oils and products of their distillation; bituminous substances, mineral waxes and is defined as follows: (h) lubricating oil means any oil, which is ordinarily used, for lubrication, excluding any hydrocarbon oil, which has its flash point below 93.3º C; And is assessed as Tariff Item: 2710 19 80 - Lubricating oil Whereas on the other hand brake Fluids falls under Sectio .....

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oleum oils or oils obtained from bituminous minerals: 3819 00 10 - Hydraulic brake fluids. In view of the aforesaid, it is crystal clear that since both the lubricating oil and brake fluid are classified under two different sections and chapters of the first schedule to the Central Excise Tariff Act 1985 therefore both of them are altogether different products and brake fluid can not be classified under the head of lubricating oil . 20- Further more the functions and composition of both Brake Fl .....

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fluid used in hydraulic brake and hydraulic clutch applications in automobiles, motorcycles, light trucks, and some bicycles. It is used to transfer force into pressure, and to amplify braking force. It works because liquids are not appreciably compressible-in their natural state, the component molecules do not have internal voids and the molecules pack together well, so bulk forces are directly transferred to compress the fluid's chemical bonds. Most brake fluids used today are glycol-ether .....

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lic brake system. 6 - As per http://www.definitions.net/definition/brake%20fluid: Brake fluid is a type of hydraulic fluid used in hydraulic brake and hydraulic clutch applications in automobiles, motorcycles, light trucks, and some bicycles. It is used to transfer force into pressure, and to amplify braking force. It works because liquids are not appreciably compressible - in their natural state the component molecules do not have internal voids and the molecules pack together well, so bulk for .....

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hly. 9 - As per http://dictionary.reverso.net/english-definition/brake %20fluid: An oily liquid used to transmit pressure in a hydraulic brake or clutch system. 10 - As per http://www.my-cardictionary.com/brake/brake-fluid . html: Function: The brake fluid must transmit the pedal force applied by the driver of a car to the wheel brakes. As soon as the driver presses the brake pedal, the force from his foot is exerted on the brake servo the via the pedal. The master brake cylinder converts the am .....

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uid. This results in high temperatures which, in extreme cases, can cause the brake fluid to boil. However, when the brake fluid starts to boil, the brake pedal slackens and the braking power drops significantly. When brake fluid boils, vapour locks are produced that can be compressed. Brake pulses are no longer sent to the wheel brakes, the brake pedal goes all the way to the floor and that dreaded moment when nothing happens at all occurs. It is for this reason that the boiling point of a brak .....

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ing point drops. The temperature known as the wet boiling point is reached at a water content level of 3.5%. Once this point in time has been reached, the brake fluid must be changed. The actual boiling point of the brake fluid can be determined in a garage using a test device. This test should be carried out annually. To safeguard the function of the brake system, the quality of the brake fluid must meet the specifications defined by the vehicle manufacturer. Furthermore, the prescribed interva .....

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the wrong viscosity can have fatal consequences for the function of modern brake systems. Definition of Lubricating Oil in various online Dictionaries: 1 - As per https://www.merriam-webster.com/dictionary/ lubricating %20oi l: An oil (as a petroleum distillate or a fatty oil) used as a lubricant. 2 - As per https://en.wikipedia.org/wiki/Lubricant : A lubricant is a substance, usually organic, introduced to reduce friction between surfaces in mutual contact, which ultimately reduces the heat ge .....

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com/words/lubricating-oil Any oil that is used or is suitable for lubrication; specifically, a thick oil produced in the process of refining paraffin-oil and petroleum. The aforesaid discussion on Brake Fluid and Lubricants makes it very clear that by no stretch of imagination Brake Fluid can be treated as Lubricant. The function of both the liquids is different. 21- The Hon'ble Supreme Court in the case of Atul Glass Industries (P.) Ltd. Vs. Union of India reported in Sales Tax Cases (Vol-6 .....

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hen a consumer buys an article, he buys it because it performs a specific function for him. The Glass Mirrors were held not to be included in item No.23A(4) of Schedule-I appended to Central Excise and Salt Act, 1944 which was relating to other Glass and Glassware. The apex Court in the aforesaid case has held as under:- A broad description of the process through which a glass sheet passes has been detailed earlier. It indicates clearly to our mind that the original glass sheet undergoes a compl .....

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he original glass sheet. What was once a glass piece in its basic character has no longer remained so. It has been reduced to a mere medium. That is clear if regard is had to the fundamental function and qualities of a glass mirror. The power to reflect an image is a power derived not from the glass piece but principally from the silvering and other processes applied to the glass medium. If any part of the coating is scratched and removed, that particular area of the glass mirror will cease to b .....

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as a glass. For the same reason, it cannot be classified as 'glass ware', for 'glass ware' means merchandise made of glass and understood in its primary sense as a glass article. A glass bowl, a glass vase, a glass tumbler, a glass table-top and so on are all articles in which the primary component is glass. They are nothing more and nothing less. Any treatment of an ornamental nature applied to such articles does not derogate from their fundamental character as glass articles. .....

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ointed out that while paper would be understood as meaning a substance which was used for writing or printing or drawing on or for packing or decorating or covering the walls, carbon paper, which is manufactured by coating the tissue paper with a thermosetting ink based mainly on wax, non drying oils, pigments and dyes could not be so described. The test commonly applied to such cases is: How is the product identified by the class or section of people dealing with or using the product? That is a .....

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in common parlance. On the same basis the Orissa High Court held in State of Orissa v. Gestetner Dluplicators (P) Ltd. [1974] (33) S.T.C. 333 that stencil paper could not be classified as paper for the purposes of the Orissa Sales Tax Act. It is a matter of common experience that the identity of an article is associated with its primary function. It is only logical that it should be so. When a consumer buys an article, he buys it because it performs a specific function for him. There is a menta .....

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uring the mirror. The basic or fundamental character of the article lies in its being a mirror. It was observed by this Court in Delhi Cloth and General Mills Co. Ltd. v. State of Rajasthan & Ors. [1980] (3) S.C.R. 1109. Which was a case under the Sales Tax law: "In determining the meaning or connotation of words and expressions describing an article or commodity the turnover of which is taxed in a sales tax enactment, if there is one principle fairly wellsettled it is that the words or .....

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attracted. Indian Aluminium Cables Ltd.v. Union of India and Others. [1985]) (3) S.C.C. 284. The question whether thermometers, lactometers, syringes, eyewash glasses and measuring glasses could be described as 'glass ware' for the purpose of the Orissa Sales Tax Act, 1947 was answered by the Orissa High Court in State of Orissa v. Janta Medical Stores [1976]) (37) S.T.C. 33. In the negative. To the same effect is the decision of this Court in Indo International Industries v. Commissione .....

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as 'glass ware for the purpose of a Notification issued under the U.P. Sales Tax Act. The decision of the High Court rested on the manner in which the contextual setting was altered in successive and different Notifications promulgated under the U.P. Sales Tax Act, indicating the content of the expression as developed through successive Notifications. Our attention has been drawn on behalf of the Revenue to the circumstance that glass mirrors have been classified as 'glass and glass ware .....

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framed in accordance with the Brussels Tariff Nomenclature, evidently because the progress made in industrial growth and economic development, and the substantial changes in the composition and pattern of India's external trade called for the need to modernise and rationalise the nomenclature of India's Tariff in line with contemporary conditions. The glass mirrors were still not specifically mentioned under the Customs Tariff Act, 1975. They are now being brought in as such by the Custo .....

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eral Mills, [1963] Supp. (1) S.C.R. 586, but was regarded as supportive material only of the expert opinion furnished by way of evidence in that case. The considerations to which we have adverted should, in our opinion, have greatly weighed in deciding the question raised in this appeal. So also in Union Carbide Co. Ltd. v. Assistant Collector of Central Excise and Others, [1978] E.L.T. 180, the description set forth in the publications of the Indian Standards Institution was regarded as a piece .....

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ed Glass Mirror as Glass only. 23- In the case of Commissioner, Trade Tax, U. P., Lucknow Vs. H. C. S. Comnet System Ltd. reported in [2014] 72 VST 383 (All), the Allahabad High Court was dealing with an issue relating to VSAT and the issue before the Court was whether VSAT (Very Small Aperture Terminals) and Satellite Receiver can be treated as one entry or the two item separately. The Allahabad High Court in the aforesaid case has held as under:- People dealing in electronic goods and items li .....

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ry 75(i) and 75(ii), it would be covered by entry 75(iii), being an item of electronic goods, not covered by any other item in entry 75 and would be taxable under entry 75(iii). 24- The apex Court in the case of Commissioner of Sales Tax, U. P. Vs. Macneill & Barry Ltd. reported in Sales Tax Cases (Vol.61) 76 was dealing with an issue relating to Ammonia Paper or Ferro Paper. The apex Court by taking into account the meaning as per common parlance has held that Ammonia Paper and Ferro Paper .....

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esting it from commercial parlance test. 26- The Division Bench of Madhya Pradesh High Court in the case of Perfetti Van Melle India Pvt. Ltd. Vs. Asst. Commissioner of Commercial Tax & Others reported in (2011) 19 STJ 560 (MP) has decided an issued relating to payment of Commercial Tax in respect of chewing gum and bubble gum. The issue was that whether the chewing gum and the bubble gum were covered under the entry 'lozenges'. The High Court has arrived at a conclusion that chewing .....

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g, i.e., the meaning which people conversant with the subject-matter with which the statute is dealing would attribute to it. For finding out the true meaning of the entries mentioned in the Sales Tax Act, what is relevant is not the educational meaning, but how those entries are understood in common parlance especially in commercial circles since sales tax primarily deals with dealers who are engaged in commercial activities. It is also the general principle that if a statute contains language .....

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61 STC 318 (SC); [1986] 2 SCC 103 and Pappu Sweets and Biscuits v. Commissioner of Trade Tax, U.P., Lucknow reported in [1998] 111 STC425 (SC); [1998] 7 SCC 228). 8. Keeping in view the aforesaid, it is to be seen, if in the common parlance chewing gum and bubblegum are treated as "lozenges". Chewing gum and bubblegum not only have different ingredients, taste features and characteristics, but they are also items different from lozenges in common parlance inasmuch as a customer asking .....

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at). When we apply common parlance test and in fact ask someone to bring the sweets from the market, he will never bring bubblegum. In common parlance, even items of confectionery will not be construed as sweetmeat (mithai). In fact, bubblegum is not an item for eating. It is kept in the mouth and after chewing the same is thrown out. The bubblegum while kept in the mouth by the children is also inflated as a balloon. In fact, it is used as a 'mouth freshener'. It is not made only of sug .....

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ontrolling the breath. In common parlance also nobody treats it as an item of confectionery. I, therefore, hold that chewing gum is an unclassified item'." 10. The same issue had come up before the Full Bench of the M.P. Commercial Tax Appellate Board in the case of this very petitioner for another assessment period where the Full Bench of the Board, after examining the matter in detail, by order dated January 31, 2004 found that the lozenges and chewing gums/bubblegums are identified d .....

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is left in the mouth. That is how the children and people in the popular sense or in common parlance identify these goods." 11. The Full Bench of the Board in the above order had also taken note of the scope of entry No. 21, Part IV of the Second Schedule and found that the bubblegums and chewing gums cannot be held to be covered under that entry as they are different from the items mentioned in that entry and therefore chewing gums and bubblegums fall in the residuary entry. The Full Benc .....

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goods of different category. It is accepted principle of law that in case of controversy of tax on commodities, one of the principles which is usually applied, is known as doctrine of 'noscitur a sociis'. i.e., where two or more words are stated together they are to be construed in a cognate manner. To put it differently, each word takes colour from each other. One application of the above general principle is the doctrine of 'ejusdem generis' which say that wherever the general .....

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honourable Supreme Court of India in its various judgments, the Appellate Board has come to the conclusion that goods 'bubblegum' and 'chewing gum' cannot be covered in entry No. 21(ii) of part IV of the Second Schedule to the Act as these goods are quite different from those already mentioned in that entry. Therefore, they cannot be taxed at the rates prescribed for that entry goods. Consequently order dated July 5, 2001 and dated August 22, 2000 passed by the Appellate Deputy .....

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the case of State of Jharkhand and Others Vs. LA Opala R. G. Ltd. reported in [2014] 70 VST 342 (SC) has again dealt with an issue of classification and has held that in the taxing statutes the terms and expression must be seen in their common parlance and not be attributed their scientific and technical meanings. The apex Court in the aforesaid case in paragraph No.26 has held as under:- 26. It is a settled law that in taxing statutes the terms and expressions must be seen in their common and .....

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up of people or things with similar qualities or features that make them different from other groups and form as the particular way in which something appears or exists or a shape of someone or something. Therefore, types are based on the broad nature of the item intended to be classified and in terms of forms , the distinguishable feature is the particular way in which the items exist. An example could be the item wax . The types of wax would include animal, vegetable, petroleum, mineral or syn .....

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Mr. Mehta that when identity of the goods on the basis of commercial parlance is similar, the High Court would have been well advised to follow the principles set out in the aforesaid decision and should not have been guided by the concept of enumeration in the Notification. In essence, the submission is that there is no distinction between the oil cake and the de-oiled cake and both should be perceived as one in commercial parlance. Thus, the emphasis is on the commercial parlance test. To bols .....

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Produce Market Committee vs. Biotor Industries Limited and Anr.[13] . In the said case, the two-Judge Bench had posed five questions and the question pertinent for our purpose reads thus:- 13.4 Whether the Division Bench is justified in recording the finding on the second issue (see para 7, above at p.737 c-d) in connection with LPA NO. 195 of 2006 that the respondent concern is not liable to pay any market fee on the de-oiled cakes sold by it which are stated to be the by-product in the course .....

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dgment that the Court has arrived at a definite conclusion that there is a distinction between the oil-cake and de-oiled cake and they are two different commercial products. Thus, when the difference has been drawn by this Court, the assessee herein cannot be allowed to advance a plea that the said test should not be applied, but the commercial parlance test should be adopted to determine the said goods for the purposes of Central Sales Tax Act. To have a complete picture, we may refer to the No .....

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or commerce, to a registered dealer or the Government shall be calculated at the rate of two per cent subject to production of declaration in Form 'C' or certificate in Form 'D' duly filed and signed by the registered dealer or the Government to whom the said goods are sold:- 1. Cotton Yarn 2. Bicycles 3. Chemical fertilizers and chemical fertilizer mixtures 4. Edible oil - refined and non-refined 5. Khandasari Sugar 6. Liquid Glucose, Dextrine, Maixe Starch, gluten, grits, maiz .....

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ification, we are obliged to hold that the High Court has correctly distinguished the authority in M/s Sterling Foods (supra) and we unhesitatingly agree with the same. 20. Though we have agreed with the said conclusion of the High Court, yet the fact remains that the assessing authority had expressed the opinion with regard to the rate of tax on the de-oiled cake while scrutinizing C Forms which is an expression of opinion on the available materials brought on record and, therefore, the first a .....

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ibunal that oilcake and de-oiled cake are the same product and, therefore, both are liable to reduced rate of tax despite the notification only mentions oil-cake, is not defensible. 30- This Court in light of the aforesaid judgments is of the considered opinion that the Brake Fluid is a different kind of liquid altogether which is never used for the purpose of lubrication. Earlier the braking system in vehicles used to be mechanical braking system, like the braking system which we have in bicycl .....

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