Sodium silicate classified as a chemical of all kinds where used in soap manufacture, rejecting the filler-only argument.

Sodium silicate used in soap manufacture was treated as a chemical compound with a definite composition and diverse industrial uses, not merely as a filler in cheap soap. On that basis, it fell within the expression "chemicals of all kinds" in item No. 7 of Notification No. ST-905/X issued under the U.P. Sales Tax Act. The contrary reasoning that it was only a filler and not a chemical compound was rejected, and the classification issue was answered in favour of the revenue and against the assessee.

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Issues: Whether sodium silicate, as used in the manufacture of soap, falls within the expression "chemicals of all kinds" in item No. 7 of Notification No. ST-905/X dated 31 March, 1956 issued under section 3-A of the U.P. Sales Tax Act.

Analysis: Sodium silicate was held to be a chemical compound with a definite, ascertainable composition notwithstanding slight variations in formula. Its uses were shown to be diverse and not confined to serving as a filler in cheap soap; it also functions as a detergent and has important industrial applications. The assessee itself manufactured sodium silicate and used it in soap manufacture, so it could not be treated as something other than a chemical merely because of one of its uses. The reasons adopted in revision, namely that sodium silicate was only a filler and not a chemical compound, were rejected.

Conclusion: Sodium silicate, as used in the manufacture of soap, is included in "chemicals of all kinds" and the question was answered in the affirmative, against the assessee.

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