HEALTHWAYS DAIRY PRODUCTS CO. vs UNION OF INDIA

The Supreme Court held that 'condensed skimmed milk' is distinct from 'condensed milk' under the exemption Notification issued under r. 8(1) of the Central Excise Rules, 1944. The Court emphasized that the common understanding of goods must be considered for tax purposes, and the Government's own classification treated the two products separately. The appeal was allowed, confirming that the appellant's product fell within the exemption and was not subject to excise duty, despite the lack of a manufacturing license for condensed skimmed milk.