COMMISSIONER OF CENTRAL EXCISE, LUCKNOW vs M/S. CHHATA SUGAR CO. LTD.

The Supreme Court clarified the distinction between 'tax' and 'fee' under Article 366(28) of the Constitution of India, emphasizing that the terms are not interchangeable and must be interpreted according to their legislative context. The Court held that a regulatory fee may, in effect, be a tax if no specific service is rendered in exchange for it. The judgment reaffirmed the principle that the imposition of a charge must align with the statutory provisions governing taxes and fees, as established in prior cases such as The Corporation of Calcutta vs. Liberty Cinema and Municipal Corporation, Amritsar vs. The Senior Superintendent of Post Offices.