Stainless steel classification fails where the essential character of a fountain-pen nib comes from its iridium tip, not steel.

Fountain-pen nibs were held not to fall within item 109 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 as articles made of stainless steel. The applicable test was whether stainless steel formed the substantial character of the commodity. That test was not met because the iridium tip was the essential and most valuable part of the nib, and the steel component did not constitute its dominant character. Accordingly, the revenue's classification failed, and the commodity was outside item 109.

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Issues: Whether fountain-pen nibs fall under item 109 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 as articles made of stainless steel.

Analysis: The relevant test was whether the article was substantially made of stainless steel. A fountain-pen nib was found not to satisfy that test because its essential and most valuable part was the iridium tip, without which the nib would be useless or far less useful as a nib. The steel component was not the substantial character of the article.

Conclusion: Fountain-pen nibs do not fall under item 109 of the First Schedule as articles made of stainless steel, and the classification claimed by the revenue fails.

Ratio Decidendi: For a commodity to be treated as an article made of stainless steel, stainless steel must form its substantial character; if the essential and dominant component is something else, the commodity does not fall within that item.

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