COMMR. OF S.T., M.P. vs M/S. POPULAR TRADING CO

The Supreme Court held that 'watery coconut' does not fall under the taxable category of 'oil seeds' as defined in the Madhya Pradesh Sthaniya Kshetra Me Mal Ke Prvesh Par Kar Adhiniyam, 1976. The Court affirmed the High Court's decision that 'watery coconut' is distinct from 'copra' and is not subject to entry tax, emphasizing that the burden of proof lies with the Department to classify 'watery coconut' as 'copra'. The judgment reinforced the interpretation of statutory language, particularly the phrase 'that is to say' as being descriptive and exhaustive.