Inclusive definition of cotton fabrics governs exemption; tarpaulin with cotton base retained exempt character despite minor processing.

Where a sales tax entry adopts an inclusive definition of "cotton fabrics" from another statute, exemption depends on that adopted definition rather than a common parlance test. Tarpaulin or cotton canvas with a cotton base, even if cut to size, stitched at the ends, and fitted with eyelets, retained its essential character as cotton fabric because the processing did not change its basic identity. The article therefore remained within item No. 5 of the Fourth Schedule to the Andhra Pradesh General Sales Tax Act, 1957, and was exempt from tax under section 8.

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Issues: Whether tarpaulin or cotton canvas sold by the assessee fell within the expression "cotton fabrics" in item No. 5 of the Fourth Schedule to the Andhra Pradesh General Sales Tax Act, 1957 and was therefore exempt under section 8 of the Act.

Analysis: Item No. 5 of the Fourth Schedule adopted the meaning assigned to "cotton fabrics" in the Additional Duties of Excise (Goods of Special Importance) Act, 1957, which in turn referred to item 19 of the First Schedule to the Central Excises and Salt Act, 1944. The relevant definition was an inclusive one and extended to fabrics manufactured wholly or partly from cotton as well as fabrics impregnated, coated or laminated with preparations of cellulose derivatives or other artificial plastic materials. The goods in question were waterproof cloth with cotton base and were not disputed to satisfy the cotton-content requirement. The mere fact that the canvas was cut to size, stitched at the ends and fitted with eyelets did not alter its essential character. Decisions applying a common parlance or user-based approach under different statutory entries were distinguished because the present entry incorporated the Central Excise definition.

Conclusion: Tarpaulin fell within "cotton fabrics" under item No. 5 of the Fourth Schedule and was exempt from tax.

Ratio Decidendi: Where a sales tax entry adopts an inclusive definition from another statute, the scope of exemption is governed by that adopted definition, and a processed or fitted cotton-base article remains "cotton fabrics" if its essential character is unchanged.

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