Exhaustive declared-goods list under sales tax law excluded steel tubes before amendment, leaving them taxable at higher rate.

Section 14(iv) of the Central Sales Tax Act, 1956 was treated as an exhaustive list of "iron and steel" goods because the words "that is to say" confined the class to items specifically named. Steel tubes were not included in that list for the relevant assessment years before 1 April 1973, and their later insertion by the 1972 amendment indicated that they were not covered earlier. On that basis, steel tubes were not entitled to declared-goods treatment at the lower rate and were taxable as mill stores at 6 per cent for those years.

---

---

Issues: Whether steel tubes were covered by clause (iv) of section 14 of the Central Sales Tax Act, 1956 as declared goods and taxable at the lower rate, or whether they remained taxable as mill stores at the higher rate for the assessment years before 1 April 1973.

Analysis: Clause (iv) of section 14 of the Central Sales Tax Act, 1956, as it then stood, contained an exhaustive enumeration of the goods falling within the expression "iron and steel". The words "that is to say" were read as limiting the category to the items specifically listed. Steel tubes were not included in that list for the relevant assessment years. Their later inclusion by section 11(b) of the Central Sales Tax (Amendment) Act, 1972, with effect from 1 April 1973, showed that they were not covered earlier. The revising authority therefore could not rely on the rate applied in the preceding year to treat steel tubes as declared goods.

Conclusion: Steel tubes were not covered by section 14(iv) of the Central Sales Tax Act, 1956 for the relevant assessment years and were liable to tax as mill stores at 6 per cent. The revision was rightly allowed in favour of the Revenue.

---