Exemption for iron and steel covered re-rolled bars, flats and plates that retained the original material's commercial identity.

Goods obtained by re-rolling scrap iron into bars, flats and plates retained their essential character as iron and steel for exemption purposes. The exemption notification had to be read with the corresponding taxing entry, which distinguished between raw materials and goods merely prepared from them. Because the processed articles were only changed in form for convenience of sale and not in substance, they continued to fall within "iron and steel" in the commercial sense adopted by the notification. The exemption therefore applied to the re-rolled products.

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Issues: Whether iron bars, flats and plates obtained by re-rolling scrap iron continued to fall within the expression "iron and steel" in item 39 of the exemption notification.

Analysis: The exemption notification had to be read with the corresponding taxing notification, which distinguished between raw iron and steel as materials and goods prepared from iron and steel. The material was only re-rolled into bars, flats and plates for convenience of sale and did not lose its character as iron and steel. The processed articles were therefore still iron and steel in the commercial sense adopted by the notification.

Conclusion: The iron bars, flats and plates were exempt as iron and steel, and the answer is in favour of the assessee.

Ratio Decidendi: Where goods retain their essential character as the original raw material and are merely changed in form for sale, they continue to fall within an exemption for that raw material unless the notification clearly excludes the processed form.

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