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14. That decision was also under the Essential Commodities Act, 1955. Similarly, in Collector of Central Excise, Bombay v. Parle Exports (P.) Ltd. , the Supreme Court answered the question whether non-alcoholic beverage bases - like Gold Spot base, Limca base or Thumps-Up base - are either "food product" or "food preparation" in terms of the exemption notification issued under rule 8 of the Central Excise Rules, 1944, as follows :

".......... In this case, therefore, it is necessary to endeavour to find out the true intent of the expressions 'food products and food preparations', having regard to the object and the purpose for which the exemption is granted bearing in mind the context and also taking note of the literal or common parlance meaning by those who deal with those goods, of course bearing in mind, that in case of doubt only it should be resolved in favour of the assessee or the dealer avoiding, however, an absurd meaning. Bearing the aforesaid principles in mind, in our opinion, the Revenue is right that the non-alcoholic beverage bases in India cannot be treated or understood as new 'nutritive material absorbed or taken into the body of an organism which serves for the purpose of growth, work or repair and for the maintenance of the vital process' and an average Indian will not treat non-alcoholic beverage bases as food products or food preparations in that light." (Emphasis [Here italicised] supplied).