Commercial tax classification must reflect local industrial conditions; revision failed for lack of material supporting heavy chemical treatment.

Lime manufactured from sea-shells was held not to be mechanically treated as a heavy chemical under item 79 of the Second Schedule to the Karnataka Sales Tax Act, 1957. The Court read the undefined entry in the statutory context and local industrial conditions, noting that lime in India was mainly produced by baking sea-shells in country kilns. Because the revisional authorities had no adequate material to support classification under that entry, they could not revise the assessment under section 21. The revision was therefore unjustified.

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Issues: Whether, on the material before the revisional authorities, lime manufactured from sea-shell could be treated as a heavy chemical under item 79 of the Second Schedule to the Karnataka Sales Tax Act, 1957, so as to justify revision of the assessment under section 21.

Analysis: The expression "heavy chemicals" was not defined in the Act, and the Court read the entry in the context of the statutory scheme and the nature of the industry in India. Although dictionary and encyclopaedic meanings suggested that heavy chemicals are bulky chemicals produced on a large scale, the Court held that those broad characteristics could not be mechanically applied without regard to the local industrial setting. Lime in India was shown to be produced mainly by baking sea-shell in country kilns, and there was no adequate material before the revisional authorities to support the conclusion that such lime was a heavy chemical. In the absence of sufficient material, the revisional authorities could not interfere with the assessment orders under section 21.

Conclusion: The revision of the assessment was unjustified, and the State's revision petitions failed.

Ratio Decidendi: A revisional authority cannot classify goods under a taxing entry and enhance assessment in the absence of adequate material showing that the goods fall within that entry, and the meaning of a commercial tax classification must be applied in the context of the relevant local industrial conditions.

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