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Issues: Whether the product marketed as "Vim" is a "soap" within item 48 of the First Schedule to the Andhra Pradesh General Sales Tax Act, so as to attract levy at the first point of sale under section 5(2)(a).
Analysis: The dispute turned on the correct classification of the product for sales tax purposes. The Tribunal had treated "Vim" as a cleansing powder distinct from soap on the basis of its ingredients, use, and properties. The Court examined the composition and manufacturing process of soap and found that soap base is used even in the preparation of scouring powders such as "Vim". Since the product shared the essential characteristics of soap and differed only by the addition of silica and builders, it was not excluded from the scope of item 48. The relevant inquiry was whether the commodity, in substance, answered the description of soap for the purpose of the taxing entry.
Conclusion: "Vim" was held to be a soap within item 48 of the First Schedule to the Andhra Pradesh General Sales Tax Act and therefore taxable accordingly.
Ratio Decidendi: For classification under a sales tax entry, a product is to be treated according to its essential composition and character, and a cleansing preparation that retains the soap base and essential properties of soap falls within the entry for soaps.