Tariff classification of laminated sheets favours the specific plastic entry over broader general descriptions.

Laminated sheets, being made of plastic layers with plastic as the basic raw material, were held to fall within the specific taxing entry for articles made of plastic rather than the broader description covering cement and asbestos sheets, hardboards, plywood and the like. In tariff classification, the full language of the specific entry must be given effect, and a commodity squarely covered by that entry cannot be shifted to another by broad interpretation. Use of the goods is not the sole test, and any ambiguity in classification must be resolved in favour of the assessee.

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Issues: Whether laminated sheets were classifiable under entry 110 of the Second Schedule to the Karnataka Sales Tax Act as plastic sheets and articles made of plastic, or under entry 78 as cement and asbestos sheets, hardboards, plywood and the like.

Analysis: Laminated sheets were found to be made of plastic layers, with plastic as the basic raw material, and therefore answered the description of articles made of plastic. Entry 110 specifically covered all articles made of plastic, whereas entry 78 covered other specified materials and only extended to similar articles by the words "and the like". In a taxing statute, effect must be given to the full language used, and a commodity falling squarely within a specific entry cannot be shifted to another entry by a broad interpretative process. The use to which the goods may be put was held not to be the sole test for classification, and any ambiguity in tariff classification must be resolved in favour of the assessee.

Conclusion: Laminated sheets fell under entry 110 and not entry 78.

Final Conclusion: The classification adopted by the revising authority and the Tribunal was set aside to the extent it treated turnovers of laminated sheets as falling outside entry 110, and the revision petitions were allowed.

Ratio Decidendi: Where a commodity is specifically covered by a taxing entry in clear terms, that specific entry prevails over a broader residuary-like description, and any unresolved doubt in classification must operate in favour of the assessee.

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