Processed rubber sheets are distinct from latex and fall outside a schedule entry limited to raw rubber.

RMA graded rubber sheets were held to be a processed commercial product distinct from latex, and therefore outside item 74 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 during the relevant period. The entry, as amended then, was confined to raw rubber, viz., latex, and the amendment history showed no extension to processed rubber sheets. As a result, purchase turnover in RMA graded rubber sheets was not liable to tax under that entry, and the consequential penalty could not be sustained.

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Issues: Whether RMA graded rubber sheets fall within item 74 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, as "raw rubber, viz., latex", so as to attract sales tax at the purchase point and sustain the consequential penalty.

Analysis: Item 74, as amended during the relevant assessment years, covered raw rubber, viz., latex, and later natural rubber latex and other varieties and grades of raw rubber. The materials placed before the Court showed that latex is a milky liquid crop obtained from rubber trees, marketable in drums or containers, whereas RMA rubber sheets are a processed product obtained from latex, packed in bales, and traded as a separate commercial commodity. The history of the amendments to item 74, together with the commercial and functional distinction between latex and RMA sheets, showed that the legislative entry during the relevant period was confined to latex and did not extend to processed RMA graded rubber sheets.

Conclusion: RMA graded rubber sheets did not fall within item 74 as raw rubber, viz., latex, and the purchase turnover was not exigible to sales tax under that entry; the consequential penalty also could not be sustained.

Ratio Decidendi: Where a tariff or schedule entry is confined to raw latex, a commercially distinct processed rubber sheet product cannot be brought within that entry merely because it is derived from latex.

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