Forging-based classification of a product under iron and steel entry cannot be revised absent an error of law.

A sales tax tribunal's finding that a product was manufactured by forging could not be disturbed in revision unless an error of law was shown. The record indicated that the article was made only through a forging process, with the hole formed by heating and forging the metal with dies rather than by drilling, turning or grinding. On that factual basis, the product was treated as falling within the iron and steel entry under section 14 of the Central Sales Tax Act, and the claimed tax exemption classification was left undisturbed.

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Issues: Whether "beater" manufactured by the assessee was covered by the term "forging" in the list of "iron and steel" under section 14 of the Central Sales Tax Act and was therefore exempt from tax.

Analysis: The material on record, including the survey report and other certificates relied upon by the Tribunal, showed that the manufacturing of "beater" involved only a forging process and that the hole in the beater was made by heating and forging the metal with dies, not by drilling, turning, or grinding. The Tribunal's conclusion that the article was manufactured by forging was thus based on evidence and constituted a finding of fact. In revisional jurisdiction under section 11 of the U.P. Sales Tax Act, such a factual finding could not be interfered with in the absence of any error of law.

Conclusion: "Beater" was held to be manufactured by forging and to fall within the relevant iron and steel entry under section 14 of the Central Sales Tax Act. The revision failed.

Final Conclusion: The tax exemption classification accepted by the Tribunal was left undisturbed, and the revision was rejected on the ground that no legal error was shown in the Tribunal's factual finding.

Ratio Decidendi: A factual finding by the sales tax tribunal that a product is manufactured by a particular process cannot be disturbed in revision unless it discloses an error of law.

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