As per the case facts the appeals were preferred by a State-owned undertaking engaged in the wholesale and retail trade of beverages challenging a common High Court judgment The core ... issue revolved around the classification of certain fees and charges under the Income-tax Act The question arose whether gallonage fee license fee and shop rental with respect to FL- and FL- licenses and also surcharge on sales tax and turnover tax would fall within the purview of a specific section of the Income-tax Act Finally the Supreme Court held that the gallonage fee license fee and shop rental squarely fall within the purview of Section a iib of the Income-tax Act but the surcharge on sales tax and turnover tax are not fees or charges within the scope of the said section

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