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Issues: Whether cast iron scrap falls within the expression "iron scrap" in entry 4(a) of the Second Schedule to the Tamil Nadu General Sales Tax Act, 1959, as it stood prior to the 1973 amendment.
Analysis: The expression "iron scrap" was held to be unqualified and broad enough to include cast iron scrap. Iron was treated as a genus and cast iron as a species, so cast iron scrap could not be excluded in the absence of words of exclusion. The later amendment expressly mentioning cast iron scrap was not accepted as an interpretive aid to narrow the earlier entry, since subsequent legislation cannot control the clear meaning of an existing provision. The entry in the Second Schedule was to be construed in its ordinary and commercial sense, rather than by strained or artificial interpretation.
Conclusion: Cast iron scrap is covered by "iron scrap" in entry 4(a) and was a Second Schedule item even before the amendment.