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Issues: Whether cotton ropes used for tying cattle fell within the expression "braided cords" in the notification granting reduced rate of tax, and whether the Board of Revenue's clarification could bind the taxing authorities.
Analysis: The notification reducing tax applied only to braided cords. The Court held that the Board of Revenue's clarification issued to other dealers was not a statutory notification or order under section 17 of the Madras General Sales Tax Act, 1959, and could not control the enforcement of the Act. There can be no estoppel against a statute, and a departmental view or assurance cannot defeat the statutory charging and exemption scheme. On the merits, the rope manufactured by the assessee was made of strands twisted together, but the strands were not interwoven or interlaced. The word "braided" imports weaving, plaiting, or interlacing, and the significance of that word could not be ignored while construing "braided cords".
Conclusion: Cotton ropes were not "braided cords" within the notification, and the assessee was not entitled to the reduced rate of tax. The revision order restoring the assessment was upheld.