Classification of galvanised iron sheets as iron and steel depends on whether processing changes the article's essential character.

Galvanised iron sheets were treated as falling within the iron and steel entry in Notification SRO No. 138 dated 28 March 1963 because the expression "that is to say" was read as an inclusive description covering different forms of the commodity. Galvanisation and corrugation were regarded as processing methods that protect or improve the sheet without destroying its essential identity as iron. On that basis, processed sheets remained classifiable as iron and steel rather than as iron goods liable to a higher tax rate, and the applicable rate was 2 per cent for the accounting period.

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Issues: Whether galvanised iron sheets fall within entry 48 of Notification SRO No. 138 dated 28th March, 1963, as iron and steel, or are to be treated as iron goods liable to tax at a higher rate.

Analysis: Entry 48 was read as an inclusive description of iron and steel, introduced by the words "that is to say", showing that the legislature intended to cover the various forms of the commodity and not to confine the entry to untreated metal alone. Galvanisation was treated as a process that protects the sheet and improves its utility, but does not destroy the identity of the underlying iron. The Court accepted the view that processing by galvanisation or corrugation does not alter the essential character of the article so as to take it out of the iron and steel entry.

Conclusion: Galvanised iron sheets are forms of iron and steel and fall within entry 48 of Notification SRO No. 138 dated 28th March, 1963. The higher rate applied by the taxing authority was and the assessee was liable only at 2 per cent for the entire accounting period.

Ratio Decidendi: Where a tax entry uses the words "that is to say" to describe iron and steel, processed sheets retain their classification if the processing does not alter their essential character as iron.

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