Iron and steel classification turns on essential character; galvanised and corrugated sheets remain within the statutory entry.

Plain and corrugated iron sheets galvanised and corrugated by the same mill continued to fall within the iron and steel entry under Section 3-AA of the U.P. Sales Tax Act. Galvanisation and corrugation were treated as processing steps that improved utility and stiffness but did not alter the essential character or identity of the goods. As the sheets remained goods directly produced by the rolling mill and identifiable as iron and steel, they were not taxable as hardware.

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Issues: Whether plain and corrugated iron sheets, after galvanisation and corrugation by the same mill, fell within the category of iron or steel under Section 3-AA of the U.P. Sales Tax Act or were taxable as hardware.

Analysis: Section 3-AA(1)(iv) deals with iron and steel and its different varieties by the expression "that is to say". Sub-clause (d) covers goods in the form in which they are directly produced by the rolling mill. Galvanisation and corrugation were treated as processes that improve utility and stiffness but do not alter the essential character of the material. The sheets continued to retain their identity as iron and steel, and because the same mill manufactured, galvanised, and corrugated them, the goods answered the description in the relevant sub-clause.

Conclusion: The turnover of the sheets was rightly treated as falling within iron or steel under Section 3-AA of the U.P. Sales Tax Act, and not as hardware.

Ratio Decidendi: Processes such as galvanisation and corrugation do not change the essential character of iron and steel when the goods remain identifiable as such within the statutory entry.

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