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Issues: Whether sarees manufactured with pure silk yarn together with artificial silk yarn and other material could still be treated as "pure silk" textiles so as to fall within the exemption under item 8A of the Fifth Schedule to the Mysore Sales Tax Act, 1957.
Analysis: Item 8A exempted all varieties of textiles except textiles made of pure silk. The decisive question was the character of the goods actually manufactured. The materials used were not confined to pure silk yarn, but included artificial silk yarn. On the ordinary and trade understanding of the expression, textiles described as "pure silk" must be textiles manufactured only from pure silk yarn. Once artificial silk yarn forms part of the manufacture, the sarees cease to answer that description and cannot claim the exemption.
Conclusion: The sarees were not pure silk textiles within item 8A and were entitled to exemption from tax.
Ratio Decidendi: For purposes of a tax exemption for "pure silk" textiles, the expression applies only where the textile is manufactured exclusively from pure silk yarn; the inclusion of artificial silk yarn takes the goods outside the exempted category.