Cast iron castings are distinct from cast iron; executive clarifications cannot override the sales tax statute.

Cast iron castings manufactured from cast iron were treated as distinct commercial commodities and not included within the statutory expression "cast iron" in the sales tax schedules. Executive clarifications and circulars were held to represent only the Government's understanding of the statute and could not bind courts or quasi-judicial authorities. A power to remove difficulties could not be used to change the substantive levy or operate as an exemption; if exemption was intended, it had to be granted under the exemption provision and in the prescribed manner.

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Issues: Whether cast iron castings manufactured from cast iron fall within the expression "cast iron" in entry 2(i) of the Third Schedule to the Andhra Pradesh General Sales Tax Act and section 14(iv)(i) of the Central Sales Tax Act, and whether the Government's clarification issued under section 42(2) could override the statutory levy.

Analysis: The expression "cast iron" was construed in its ordinary commercial sense and was held to denote the raw material, not the finished goods made from it. The goods manufactured by the assessee, such as cast iron pipes, man-hole covers and bends, were treated as distinct commercial commodities from cast iron itself. Clarifications and circulars issued by the Central and State Governments were held to reflect only the executive understanding of the statute and not to bind the courts or quasi-judicial authorities. The order issued under section 42(2) of the State Act was held to be statutory, but the power to remove difficulties could not be used to alter the substantive levy or to grant what was, in substance, an exemption. If exemption was intended, it had to be exercised under the exemption provision and in the prescribed manner.

Conclusion: The cast iron castings manufactured by the assessee do not fall within "cast iron" in entry 2(i) of the Third Schedule to the Andhra Pradesh General Sales Tax Act or section 14(iv)(i) of the Central Sales Tax Act.

Final Conclusion: The challenge to the levy failed, and the notice-based writ challenge also failed on the same reasoning.

Ratio Decidendi: Executive clarifications cannot override the statute, and a power to remove difficulties cannot be used to nullify or substitute the substantive statutory levy; finished goods made from a declared commodity are not necessarily the declared commodity itself.

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