Raw cotton entry excludes processed absorbent cotton wool, which falls under the residuary tax item.

A tariff entry for raw cotton covers only cotton in its natural or nearly natural state, with ginning as the limited contemplated process. Absorbent cotton wool, produced from ginned cotton through cleaning, boiling, bleaching, drying and carding, is a processed finished product and not raw cotton in its ordinary commercial sense. Its continued botanical composition as cotton does not bring it within the raw cotton entry. It therefore falls under the residuary item applicable to goods not specifically covered elsewhere in the Schedule, and is taxable accordingly.

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Issues: Whether absorbent cotton wool prepared from ginned cotton by cleaning, boiling, bleaching, drying and carding fell within item 1 of Schedule B as raw cotton, or was chargeable under the residuary item 80.

Analysis: Item 1 covered raw cotton, whether ginned or unginned, and therefore extended only to cotton in its natural or nearly natural form, with ginning as the only contemplated process. Absorbent cotton wool, as prepared and sold, was a finished product obtained after multiple processing stages and was no longer raw cotton in its ordinary commercial sense. The fact that its botanical composition remained substantially cotton did not keep it within the entry. The residuary item applied to goods not specifically covered elsewhere in the Schedule.

Conclusion: Absorbent cotton wool did not fall within item 1 of Schedule B and was liable to tax under item 80. The answer was against the assessee and in favour of the Revenue.

Ratio Decidendi: A tariff entry for raw cotton covers only cotton in its natural or nearly natural state, and a processed finished product made from cotton is excluded unless specifically brought within the entry.

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