Broad leather goods entry covers football and volleyball leather covers, excluding the residuary tax rate.

Leather football and volleyball covers are covered by the specific notification entry for "all kinds of leather goods except footwear" under the amended Rajasthan sales tax framework. The controlling interpretation, already adopted by a Division Bench, treated that expression as wide enough to include leather sports covers, so the specific entry applied and the residuary entry was not available. On that basis, such goods were taxable at 7 per cent under item No. 39 rather than under the lower-rate residuary category.

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Issues: Whether football and volleyball covers made of leather fall within item No. 39 of the relevant Government Notification as "all kinds of leather goods except footwear" and are taxable at 7 per cent, or are taxable under the residuary entry at a lower rate.

Analysis: The matter was governed by the newly substituted section 15 of the Rajasthan Sales Tax Act, 1954, as amended by the Rajasthan Sales Tax (Amendment) Act, 1984. The controlling question had already been decided by a Division Bench, which held that the expression "all kinds of leather goods except footwear" is wide enough to include leather covers for footballs and volleyballs. On that reasoning, the specific entry covered the goods and there was no occasion to resort to the residuary entry.

Conclusion: Football and volleyball covers made of leather fall within item No. 39 and are taxable at 7 per cent, not under the residuary entry.

Ratio Decidendi: A broad specific tariff entry for leather goods, excluding only footwear, prevails over the residuary entry and includes leather sports covers such as football and volleyball covers.

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