Exhaustive taxing entry for iron and steel excludes galvanised sheets unless specifically listed.

A taxing entry using the phrase "iron and steel, that is to say" was treated as exhaustive, so the listed items could not be expanded by a broad commercial meaning. Applying that construction, galvanised plain and corrugated sheets were held not to fall within entry No. 23 of the 1963 notification read with section 14 of the Central Sales Tax Act, 1956, because they were not specifically named among the covered categories such as iron plates, steel sheets, or rolled steel sections. The later 1972 amendment expressly including such goods was not regarded as retrospective clarification of the earlier notification.

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Issues: Whether entry No. 23 of Notification No. F. 5(40)F.D. (R & T) 63-XIII dated 2nd March, 1963, read with section 14 of the Central Sales Tax Act, 1956, covered galvanised plain and corrugated sheets within the term "iron and steel".

Analysis: The relevant notification used the words "iron and steel, that is to say", which indicated an exhaustive and not expansive enumeration of the covered goods. After the Supreme Court's interpretation of section 14 of the Central Sales Tax Act, 1956, the expression could not be given a broad meaning so as to include every commercial article made from iron or steel. The notification specifically mentioned only certain iron and steel items, and galvanised or corrugated sheets did not fit within the listed categories such as iron plates, steel sheets, or rolled steel sections. The later amendment of 1972, which expressly included such items, could not be treated as retrospective clarification of the earlier notification.

Conclusion: Galvanised plain and corrugated sheets did not fall within the term "iron and steel" under entry No. 23 of the notification dated 2nd March, 1963.

Ratio Decidendi: Where a taxing entry uses the phrase "that is to say", the enumeration is exhaustive, and goods not specifically included cannot be brought within the entry by resort to a broad commercial or generic meaning.

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