Classification of yeast as a chemical under the specific sales tax entry, not the residuary entry.

Yeast sold in powder and granules form was analysed as a product composed of chemical constituents and used in baking through a chemical reaction and effect. On that basis, it was treated as falling within the ordinary meaning of "chemical" in the specific sales tax entry for "dyes and chemicals", rather than being pushed into the residuary entry. The absence of a separate entry for micro-organisms or biological products was not decisive, because classification depended on whether the goods answered the chemical description. The result was that yeast powder was classified under the specific chemical entry and not as a residuary commodity.

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Issues: Whether yeast sold in powder and granules form is a chemical falling within the expression "dyes and chemicals" in entry 9 of Schedule II, Part A to the Gujarat Sales Tax Act, 1969, or whether it falls under the residuary entry 13 of Schedule III.

Analysis: Yeast was found to be composed of chemical constituents and to be used in baking by producing a chemical reaction and chemical effect. The entry dealing with "dyes and chemicals" was treated as a residuary entry within its own field, so that goods not specifically placed elsewhere and answering the description of chemicals would fall within it. The absence of a separate entry for micro-organisms or biological products was not treated as decisive, because the question referred was confined to whether yeast answered the description of chemical. Applying the ordinary meaning of the word and the principle that a specific description excludes resort to a general residuary entry, yeast powder was held to be covered by entry 9 rather than the residuary entry.

Conclusion: Yeast sold in powder and granules form is a chemical within entry 9 of Schedule II, Part A, and not a residuary commodity under entry 13 of Schedule III.

Final Conclusion: The reference was answered in favour of the dealer by upholding the classification of yeast as a chemical under the relevant sales tax entry.

Ratio Decidendi: A product whose composition and use bring it within the ordinary meaning of "chemical" must be classified under the specific chemical entry and cannot be relegated to the residuary entry.

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