The constitutionality of levy of sales tax on Gingers under the Assam General Sales Tax Act, 1993 is the core question involved in this writ petition. 2. The petitioner is an Association of Kuki Ginger Producers of Karbi Anglong District in the State of Assam. According to the petitioner, the Kukies-a Scheduled Tribe within the meaning of Article 342 of the Constitution of India, traditionally grow Ginger in the Karbi Anglong District. Ginger cultivation is the main source of earning livelihood for the Kuki tribe in the rural area. Ginger being a vegetable, was not a taxable item under the Assam Sales Tax Act, 1947. Amongst others, vegetables which included ginger was an exempted item under section 7 of the Act, 1947. The Assam General Sales Tax Act, 1993, hereinafter referred to as the Act, 1993, was enacted to amalgamate, consolidate and amend the laws relating to the levy of tax on the sale or purchase of goods in the State of Assam. All sales or purchase of goods other than those goods specified in Schedule I to the Act, 1993 are made taxable under the provisions of the Act. By section 9 of the Act, 1993, subject to the conditions and exceptions, if any, set out in Schedule I to the Act, 1993, the sales of goods specified therein are exempted from tax. Schedule I to the Act, 1993 contains the list of exempted items and 'vegetables' is one of the items in the said list as cited at serial No. 39, which reads as follows: “39. Vegetables (but not onion, garlic, Except when sold spices, ginger and condiments) as cooked food.” The petitioner contents that ginger is a 'root vegetable' like potato and radish and, therefore, the question of excluding ginger from the purview of the exempted goods, is per se arbitrary. The Constitutional scheme is for protection of the socially and economically backward classes and the new measure to include ginger as a taxable commodity shall seriously affect the Kuki tribe of the Karbi Anglong District. 3. Mr. NN Saikia, the learned senior counsel appearing on behalf of the petitioner, referred to the history of the sales tax laws in Assam and submitted that keeping in mind the peculiar nature of the ginger cultivation and other like considerations, the Legislature kept ginger outside the tax net. 3. Mr. NN Saikia, the learned senior counsel appearing on behalf of the petitioner, referred to the history of the sales tax laws in Assam and submitted that keeping in mind the peculiar nature of the ginger cultivation and other like considerations, the Legislature kept ginger outside the tax net. In the Act, 1993, the Legislature in its wisdom thought it fit to exempt the 'vegetables' from sales tax, but, amongst others, excluded ginger from the list of exempted items. Mr. Saikia, the learned senior counsel, submitted that ginger is out and out a vegetable and, therefore, there cannot be any justification from not exempting sales or purchase of ginger from taxation. In support of his contention, the learned senior counsel appearing oh behalf of the petitioner, referred to the decisions in 13 STC 838, Krishna lyer vs. State of Kerala; and 39 STC 378, State of WB & others vs. Washi Ahmed & others. Mr. Saikia, the learned senior counsel argued at length the likely effect of the legislation on the ginger producers in general and the petitioner in particular. Lastly, Mr. Saikia submitted that sales of ginger, since takes place at Dimapur in the State of Nagaland and outside the State of Assam, the same is not taxable under the State law of Assam in view of Article 286 of the Constitution of India. In support of this contention, Mr. Saikia referred to the decision of the Supreme Court in the case of Malayalam Plantation Ltd vs. Deputy Commissioner of Agricultural Income lax and Sales Tax, reported in AIR 1965 SC 161 . The last question/point need to detain us for the simple reason that the Act in question is only applicable with respect to sale or purchase of goods in the State of Assam. 4. Opposing the writ application, Shri HN Sarma, the learned Addl Senior Govt Advocate submitted that the legislative competence of the Legislature to levy tax on the sale and purchase of goods is not in question, what is in question is the levy of tax on sale or purchase of ginger. The Legislature has the freedom to decide on the subject matter in question in imposing tax liability and in the absence of contravention of any Constitutional provision, the legislative discretion is not to be readily interfered with. The Legislature has the freedom to decide on the subject matter in question in imposing tax liability and in the absence of contravention of any Constitutional provision, the legislative discretion is not to be readily interfered with. The Legislature in the case in hand exercised its discretion by exempting 'vegetables' except onion, garlic, spices, ginger and condiments and this discretion exercised by the Legislature in the absence of avowed arbitrariness, is not to be intervened. 5. Admittedly, the State Legislature under Entry No. 54 of List II of the Seventh Schedule to the Constitution is authorised to legislate with respect to taxation on sale or purchase of goods. The tax on sale of ginger can be levied in conformity with the Constitutional provisions. The legislative competence is never in question. The power to legislate is given by Article 246 of the Constitution. The three Lists of the Seventh Schedule to the Constitution are legislative heads or fields of legislation by the Union or State or by both. By the Act, 1993, the State Legislature while exempting vegetables from taxation, consciously did not exempt ginger, onion, garlic, species and condiments though it might have excluded those from the purview of taxation earlier. The Legislature has the freedom to legislate within the respective fields as allotted under the various lists under the Seventh Schedule to the Constitution. There is a permissible area of discretion on the legislature - more so in respect of taxing legislation; so much so that it is always open to the State to tax certain classes of goods and not to tax others. The State authority in .exercise of its sovereign power is free to legislate in its respective fields on different subject matter. In view of the innate complexities in the fiscal adjustments of diverse economic factors in the formulation of the policy of taxation and the variety of problems those are posed, wide options are open to the Legislature. The true nature and character of a legislation is to be judged with reference to the competence of the Legislature and not with reference to the result and effect of the legislation. The subject of taxation is different from the measure of levy. Taxing Statutes, of course, are not beyond the pale of Article 14 of the Constitution. The true nature and character of a legislation is to be judged with reference to the competence of the Legislature and not with reference to the result and effect of the legislation. The subject of taxation is different from the measure of levy. Taxing Statutes, of course, are not beyond the pale of Article 14 of the Constitution. However, one should not leave out of consideration the fact that the Legislature possesses a comprehensive and extensive power in the matter of selection of the subject, subject matters, affairs and like other b factors of taxation while formulating its fiscal measures. In assessing the inequalities or discrimination in the taxing statute(s), Courts are to take a flexible attitude in view of the complexities involved in appraising the diverse economic criteria. The State in exercise of its sovereign function, as of necessity, has the power to make laws operating with differentiation in relation to groups or classes of persons to attain its fiscal objectives-classification is inherent. It was pithily c observed by the American Supreme Court in the case of Secretary of Agriculture vs. Central Rdigh Refining Company, reported in (1949) 338 US 604 : L ed 381, that “this Court is not a Tribunal fotresolving for crudities and inequalities of complicated experimental economic legislation”. In this context, it is apt to recall the following observations of the Supreme Court in two of its decisions, viz, Jaipur Hosiery Mills Pvt Ltd vs. State of Rajasthan & others, reported in (1970) 2 SCC 26 ; and Hiralal Rattanlal, etc vs. State of UP & another etc reported in (1973) 1 SCC 216 . In Jaipur Hosiery Mills (supra), the Supreme Court held (relevant page 28, para 3): “....It has to be borne in mind that in matters of taxation the Legislature possesses the large freedom in the matter of classification. Thus wide discretion can be exercised e in selecting persons or objects which will be taxed and the statute is not open to attack on the mere ground that it taxes some persons or objects and not others. It is only when within the range of its selection the law operates unequally and cannot be justified on the basis of a valid classification that there would be a violation of Article 14.” In Hira Lal Rattan Lal (supra), the Supreme Court observed (relevant pages 222-23, paras 14,17 and 20). “... It is only when within the range of its selection the law operates unequally and cannot be justified on the basis of a valid classification that there would be a violation of Article 14.” In Hira Lal Rattan Lal (supra), the Supreme Court observed (relevant pages 222-23, paras 14,17 and 20). “... It is open to the Legislature to define the nature of the goods, the sale or purchase of which should be brought to tax. Legislature was not incompetent to separate the processed or split pulses form the unsplit or unprocessed pulses and treat the two as separate and independent goods. ... But the Legislature has wide powers of classification in the case of taxing statutes. .... The classification between the-processed or split pulses and unprocessed or unsplit pulses is a reasonable classification. It is based on the use to which those goods can be put. Hence, in our opinion, the impugned classification is not violative of Article 14.” In the case in hand, it appears that the Legislature while exempting some of the items in its wisdom from the purview of taxation under section 9 (1.) of the Act, 1993, excluded some goods from exemption. The vires of section 9 of the Act, 1993 is not in question. Section 9 of the Act, 1993 empowers the State Legislature to exempt sale of goods specified therein form taxation subject to conditions and exceptions. The State Govt is further empowered to amend or modify the Schedule to the Act by notification in the Official Gazette and for that matter make exemption or reduction in the rate of taxation in respect of any tax or interest payable under the Act, 1993. This exemption may extend to the whole of the State or to any specified area or areas therein and be subject to such other restrictions or conditions as may be specified in the notification. The legislature in its wisdom exempted 'vegetables' except when sold as cooked food, but at the same time, did not exempt onion, garlic, ginger, spices and condiments. The Legislature is within its competence to make classification of the items including vegetables. It was within its powers to except onion, garlic, spices, ginger and condiments from 'vegetables'. The classification that was brought in the instant case, cannot be said to be unreasonable classification and violative of Article 14 of the Constitution of India. 6. The Legislature is within its competence to make classification of the items including vegetables. It was within its powers to except onion, garlic, spices, ginger and condiments from 'vegetables'. The classification that was brought in the instant case, cannot be said to be unreasonable classification and violative of Article 14 of the Constitution of India. 6. In the area of fiscal legislation where the Legislature possesses both the expertise and familiarity with the local problems and necessity, the Courts are normally to defer the legislative judgments. When the legislature possesses the competence to legislate on the subject and it is clothed with the discretion to levy tax, the matter is to be left to the legislative wisdom. It is usually not the business of the Courts to consider the propriety or justness of the Act, 1993 by entering into the realm of policy. In the case in hand, the learned counsel for the petitioner has submitted that the Act in question is applicable only with respect to the sale or purchase of goods within the State of Assam and since the sales of ginger take place at Dimapur outside the State of Assam, the article in question is not taxable under the State law of Assam, as alluded earlier, in view of the provisions of Article 286 of the Constitution. If factually, the sale or purchase of goods take place outside the State of Assam, it would be open to the aggrieved persons to take up the plea before the taxing authority and that cannot be a ground for condemning the legislative process. 7. The decisions reported in 13 STC 838 and 39 STC 378, are decisions on facts and are not applicable in the fact situation of the case in hand. In the Act, 1993, the Legislature exempted 'vegetables', but specifically excluded garlic, ginger, spices, onion and condiments from the list of goods sale or purchase of which is/are exempted from taxation. In the aforesaid two cases, exemption was in respect of 'vegetables'. In the case of State of West Bengal & others v. Wash Ahmed & others, reported in 39 STC 378, the Supreme Court had the occasion to deal with a similar question wherein sales tax was levied by the Bengal Finance (Sales Tax) Act, 1941 on the taxable turnover of a dealer computed in accordance the provisions of the aforesaid Act. Sub-section (1) of section 6 of the aforesaid Act, 1941 provided that no tax was payable under the Act on sale of goods specified in the first column of Schedule I, subject to the conditions and exceptions, if any, set out in the corresponding entry in the second column thereof and item (6) of Schedule I specified in the first column vegetable, green or dried, commonly known as 'sabji, tarkari or sak' so that no tax was payable on the sale of goods falling within the said category, subject to the exceptions set out in the second column, namely, that they would be liable to bear tax “when sold in sealed containers”. A ground was taken that green ginger was not sold by the assessee in the sealed container and the only question that was, therefore, required for consideration was as to whether the green ginger could be regarded as 'vegetable' commonly known as 'sabji, tarkari or sak'. The word 'vegetable' was not defined in the above Act, 1941. It was argued that 'vegetable' in a taxing statute was to be understood in the common parlance, ie, denoting a class of vegetables which were grown in a kitchen garden or in a farm and were used for the table. The Single Judge of the High Court as well as a Division Bench of the High Court (of Calcutta) held that green ginger was a 'vegetable' within the meaning of that expression as used in item (6) of the First Schedule to the Act, 1941. On appeal under Article 136 of the Constitution, the Supreme Court refused to differ from the views expressed by the High Court and observed as follows: “It will, therefore, be seen that the word 'vegetable' in item (6) of Schedule I to the Act must be construed as understood in common parlance and it must be given its popular sense meaning that sense which people conversant with the subject matter with which the statute is dealing would attribute to if and so construed, it denotes those classes of vegetables which are grown in a kitchen garden or in a farm and are used for the. table. Now, obviously green ginger is a vegetable grown in a kitchen garden or in a farm and is used for the table. table. Now, obviously green ginger is a vegetable grown in a kitchen garden or in a farm and is used for the table. It may not be used as a principal item of the meal but it certainly forms part of the meal as a subsidiary item. It is an item which ordinarily sold by a vegetable vendor and both the vegetable vendor who everyday deals in vegetables and the housewife who daily goes to the market to purchase vegetables would unhesitatingly regard green ginger as vegetable.... .... .... That apart, we find that item (6) speaks not simply of vegetables but Vegetables - commonly known as 'sabji, tarkari or sak' and the Division Bench of the High Court held green ginger to fall within the meaning of the words 'sabji, tarkari or sak'. We should certainly be very slow to disturb a meaning placed on these words in Bengali language by two Judges of the High Court who may reasonably be expected to be quite conversant with that language. We are accordingly of the view that green ginger is included within the meaning of the words 'vegetables' commonly known as 'sabji, tarkari or sak' in item (6) of Schedule I and the sales must be held to be exempt from tax under Section 6 of the Act.” 8. In the case in hand, the Legislature has not left any doubt on the mind by specifically excluding onion, garlic, spices, ginger and condiments, from the term 'vegetables'. The words of the taxing statute is clear, unambiguous and ' unequivocal. Ginger amongst others is specifically excepted from exemption without leaving any scope for ambiguity. Equitable considerations cannot come in the way of interpretation of a taxing statute. The Court is to look straight at the words of the statute and interpret them. The Court is to interpret the statute in the light of the words clearly exercised. It cannot import anything which is not expressed. Equitable considerations cannot come in the way of interpretation of a taxing statute. The Court is to look straight at the words of the statute and interpret them. The Court is to interpret the statute in the light of the words clearly exercised. It cannot import anything which is not expressed. As said by Justice VR Krishna lyer in Martand Dairy & Farm vs. Union of India, reported in AIR 1975 SC 1492 (relevant page 1494) 'taxation consideration may stem from administrative experience and other factors of life and not artistic visualisation or neat logic and so the literal, though pedestrian, interpretation must prevail.” On overall consideration of the matter and for the reasons stated above, I do not find any merit in this writ petition and accordingly, the same is dismissed. There shall, however, be no order as to costs. The interim order (s) stand (s) vacated.