In Brief
Santhosh Maize & Industries Limited, a maize starch dealer, challenged a tax authority's decision to classify maize starch under the 4% tax rate applicable to 'sago and starch of any kind', rather than under the exemption entry for 'products of millets'. The Supreme Court held that maize starch, being a processed product derived through mechanical processing, differs from raw maize and is not covered by the millet exemption entry (which explicitly omitted the word 'like' used in the original exemption notification). As maize starch is a 'kind of starch', it falls squarely under the specific taxation entry. The Court upheld the Commissioner's clarification as valid and retrospectively applicable. Appeal dismissed.
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