Iron and steel nails are separately taxable and do not qualify for Third Schedule exemption.

Iron and steel nails are not covered by item 2 of the Third Schedule merely because they are made from iron and steel. The entry lists specific and distinct categories, and exemption does not extend to every article manufactured from those materials once tax has been paid on the basic inputs. Nails are commercially separate from wires and wire rods, and they do not qualify as defectives, rejects, cuttings or end-pieces of those categories because that phrase applies only to remnants or inferior forms of the enumerated items. Nails therefore remain separately taxable under section 5(1) of the General Sales Tax Act.

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Issues: Whether iron and steel nails are exempt from sales tax as falling within item 2 of the Third Schedule, including the categories of iron and steel, wires, wire rods, or defectives, rejects, cuttings or end-pieces, and whether they remain separately taxable commodities.

Analysis: Item 2 of the Third Schedule enumerates iron and steel products in specific and distinct categories. The ruling in the Supreme Court authority on iron and steel commodities establishes that the listed products are separate taxable items and that the entry does not extend exemption to every article made out of iron and steel merely because the basic material has already suffered tax. Nails are not enumerated as such. They are commercially distinct from wires and wire rods and cannot be treated as the same commodity in ordinary trade or use. They also do not fall within defectives, rejects, cuttings or end-pieces of the enumerated categories, because that expression applies to remnants or inferior forms of those very categories, not to a separately manufactured article like nails.

Conclusion: Nails do not fall under item 2 of the Third Schedule and are not exempt on that basis. They are taxable under section 5(1) of the General Sales Tax Act, and the revision fails.

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