Alloy classification under sales tax notification extends to brass wire containing more than one specified metal.

Under the U.P. Sales Tax Act notification, brass wire was treated as an alloy containing copper and zinc, both metals named in the entry. The Supreme Court reasoned that an alloy does not fall outside the notification merely because it contains more than one of the specified metals, unless the wording clearly limits coverage to a single metal. On that construction, brass wire was covered by the notification and fell within the taxable entry as contended by the assessee.

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Issues: Whether brass wire manufactured by the assessee fell within the notification issued under sub-section (2) of section 3-A of the U.P. Sales Tax Act as an alloy containing copper, tin, nickel or zinc, or whether it was outside the entry.

Analysis: The entry covered an alloy containing any of the named metals. Brass is an alloy of copper and zinc, so it contains metals mentioned in the entry. The presence of more than one specified metal does not take the alloy outside the entry, and the wording of the notification did not support restricting the benefit only to alloys containing a single specified metal.

Conclusion: Brass wire was covered by the notification and fell within the taxable entry in the manner contended by the assessee.

Ratio Decidendi: An alloy falls within an entry covering alloys containing any of the specified metals even if it contains more than one of those metals, unless the entry clearly restricts coverage otherwise.

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