Registration certificate scope for raw materials was construed broadly, excluding section 10(b) penalty where goods were used in manufacture.

The expression "raw materials" in a registration certificate was construed broadly where it referred to materials for manufacturing drums and used the illustrative phrase "like 26, 24 and 22 gauge CRCS sheets". The court held that "like" was descriptive and not exhaustive, so plugs, flanges, and top and bottom dies actually used as raw materials in drum manufacture fell within the certificate's scope. As there was no misuse of C forms beyond the registered purpose, section 10(b) of the Central Sales Tax Act was not attracted and penalty was not leviable.

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Issues: Whether the purchase of plugs, flanges, top and bottom die from outside the State for use in the manufacture of drums was covered by the assessee's certificate of registration, and whether such purchase attracted penalty under section 10(b) of the Central Sales Tax Act.

Analysis: The certificate of registration referred to raw materials for the manufacture of drums and used the expression "raw materials like 26, 24 and 22 gauge CRCS sheets". The expression "like" was held to be descriptive and illustrative, not exhaustive. Since the goods purchased against C forms were in fact used as raw materials in the manufacture of drums, they fell within the scope of the certificate. The attempted restriction of the expression "raw materials" to only the named items was rejected.

Conclusion: There was no violation of section 10(b) of the Central Sales Tax Act, and the penalty was not leviable.

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