Iron and steel classification: galvanised, corrugated and B.P. sheets remain covered, keeping second sales untaxed.

Galvanised plain or corrugated sheets and B.P. sheets were treated as forms of "iron and steel" under Entry No. 2 of the Third Schedule to the Andhra Pradesh General Sales Tax Act. The court applied the common parlance test but held that a different trade name or use is not decisive where processing such as galvanisation or corrugation only changes shape or utility without destroying the essential character of the material. B.P. sheets were regarded as mere steel sheets. On that basis, their second sales were not liable to tax.

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Issues: Whether galvanised plain or corrugated sheets and B.P. sheets fall within the expression "iron and steel" in Entry No. 2 of the Third Schedule to the Andhra Pradesh General Sales Tax Act.

Analysis: The expression "iron and steel" in the schedule was treated as covering all forms of that commodity, and the words "that is to say" were read as explanatory and enlarging the general concept. The common parlance or commercial understanding test was applied, but the court held that it is not decisive merely that the goods bear a different trade name or are put to different uses. Processing that only alters shape or improves utility, such as galvanisation and corrugation, does not necessarily destroy the essential character of the raw material. B.P. sheets were treated as mere sheets of steel.

Conclusion: Galvanised plain or corrugated sheets and B.P. sheets are forms of "iron and steel" within Entry No. 2 of the Third Schedule, and their second sales are not liable to tax.

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