Commissioner Of Central ... vs M/S Chhata Sugar Co. Ltd

The Supreme Court clarified the distinction between 'tax' and 'fee' as defined under Clause (28) of Article 366 of the Constitution of India, emphasizing that the terms are not interchangeable and must be interpreted based on legislative context. The Court held that a regulatory fee may, in effect, be a tax if no specific service is rendered in return, citing precedents such as The Corporation of Calcutta vs. Liberty Cinema and Municipal Corporation, Amritsar vs. The Senior Superintendent of Post Offices. The judgment reinforces the principle that the imposition of charges must align with the nature of services provided, and any charge levied without corresponding services constitutes a tax rather than a fee.