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Issues: Whether the definition of "cotton fabrics" in item 19 of the First Schedule to the Central Excises and Salt Act, 1944, as amended, applied to item 7 of the Third Schedule to the Kerala General Sales Tax Act, 1963, so as to keep rexine within the sales tax exemption.
Analysis: The exemption under the Kerala Act was linked to the central excise definition of "cotton fabrics". The cited authorities on incorporation and reference were examined to determine whether the later amendment to the parent statute automatically affected the State exemption scheme. The governing principle was that where a later enactment adopts an earlier definition in a way that is integrally connected with the working of the later Act, the later changes to the parent statute may be carried into the adopted provision, especially where a static reading would make the later Act ineffective or unworkable. On that approach, the extended central excise definition, including fabrics coated or impregnated with artificial plastic materials, had to be read into the Kerala Sales Tax Schedule entry.
Conclusion: The exemption covered the goods in question, and the revision cases succeeded.
Final Conclusion: The State sales tax entry was construed in the light of the expanded central excise definition, and the matter was sent back for determination of the refund due in accordance with law.
Ratio Decidendi: Where a State taxing entry adopts a central statutory definition that is integrally connected with the working of the State Act, later amendments to the central definition may be read into the State enactment if a contrary construction would render the State scheme unworkable or ineffectual.