New Delhi, Feb. 26 -- For generations of Indians, a glass of ruby-red Rooh Afza has meant summer relief - stirred into cold water, milk or desserts, and served at iftar tables and family gatherings alike. On Wednesday, the Supreme Court settled a long-running tax battle over the iconic drink, ruling that Sharbat Rooh Afza cannot be pushed into a higher tax bracket simply because it is marketed as a "sharbat." Noting that the drink derives its beverage identity from fruit-based ingredients and is intended for dilution and consumption, a bench of justices BV Nagarathna and R Mahadevan held that Rooh Afza qualifies as a "fruit drink" under the taxation law. The court allowed the batch of appeals filed by Hamdard (Wakf) Laboratories, the manufacturer of Rooh Afza, the court set aside 2018 judgments of the Allahabad High Court and tax authorities which had classified the product as an "unclassified" item taxable at 12.5% under the residuary entry of the Uttar Pradesh Value Added Tax (UPVAT) Act. Instead, the bench held that Rooh Afza is classifiable under Entry 103 of Schedule II (Part A) of the UPVAT Act as a "fruit drink/processed fruit product", attracting a concessional VAT rate of 4% during the relevant assessment period between January 1, 2008 and March 31, 2012. At the heart of the dispute was whether Rooh Afza, which contains 10% fruit juice blended with invert sugar syrup and herbal distillates, could legally qualify as a "fruit drink", or whether it should fall into the residuary basket meant for goods not specifically classified elsewhere. Revenue authorities had relied heavily on a clarification issued under food safety regulations stating that a "fruit syrup" must contain at least 25% fruit juice. Since Rooh Afza contains only 10%, it was described as a "non-fruit syrup containing 10% fruit juice". Rejecting this reasoning, the top court made it clear that regulatory classification under food safety law cannot control fiscal interpretation unless the taxing statute expressly adopts such definitions. "It is trite that a fiscal statute must be interpreted in its own language," said the bench. Since the term "fruit drink" was not defined in the UPVAT Act, the court applied the "common parlance test" - how the product is understood in commercial and popular sense. The bench also applied the "essential character test", holding that although invert sugar syrup constitutes around 80% of the volume, it merely acts as a carrier and preservative. The bench directed Uttar Pradesh authorities to grant refund or adjustment of excess tax paid under protest - amounting to over Rs.26 million, in accordance with law. To be sure, the ruling is confined to the VAT regime that existed prior to the rollout of the Goods and Services Tax (GST). Under GST, fruit-based drinks fall under Tariff Heading 2202 and attract 2.5% tax....