Composite iron and steel entry includes stainless steel, so stainless steel wires and tubes remained declared goods.

In a composite tariff entry using the words "iron and steel, that is to say", the expression was treated as broad enough to include alloy steel and stainless steel unless the statute clearly restricted it. Applying that construction, stainless steel wires and stainless steel tubes were held to fall within item 4 of the Second Schedule to the Tamil Nadu General Sales Tax Act as declared goods, and a narrower reading drawn from a sub-item was rejected. The Court also held that an admission-stage order on stainless steel wire was not binding because only its ratio could operate as precedent, and no reliable ratio emerged from the earlier summary decision.

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Issues: (i) Whether stainless steel wires and stainless steel tubes fall within item 4 of the Second Schedule to the Tamil Nadu General Sales Tax Act, 1959 as declared goods, and (ii) whether the earlier admission-stage decision treating stainless steel wire as an article made of stainless steel was binding.

Issue (i): Whether stainless steel wires and stainless steel tubes fall within item 4 of the Second Schedule to the Tamil Nadu General Sales Tax Act, 1959 as declared goods.

Analysis: The main entry uses the expression "iron and steel, that is to say", and the sub-items are to be read as part of the same composite entry. The expression "iron and steel" was held to include alloy steel and stainless steel, not merely non-alloy steel. The Court relied on technical and standard references, the statutory structure of the entry, and the principle that the words "that is to say" explain but do not curtail the main entry. A restrictive reading based on another sub-item was rejected, since that would diminish the scope of the main item. On that construction, stainless steel wire and stainless steel tube remained within the declared goods entry.

Conclusion: Stainless steel wires and stainless steel tubes were held to be declared goods falling under item 4 of the Second Schedule, in favour of the assessees.

Issue (ii): Whether the earlier admission-stage decision treating stainless steel wire as an article made of stainless steel was binding.

Analysis: The earlier order was rendered at the admission stage without detailed argument or a full factual foundation, and the reasoning in that order had been overtaken by the later and fuller analysis adopting the broader meaning of "iron and steel". The Court held that a decision is binding for its ratio, not merely its conclusion, and that no reliable ratio could be extracted from the earlier summary order to control the present cases.

Conclusion: The earlier admission-stage decision was held not to be binding.

Final Conclusion: The assessees succeeded on the substantive classification issue, the contrary view of the Tribunal was set aside, and the Revenue's connected appeals failed.

Ratio Decidendi: In a composite tariff entry using "iron and steel, that is to say", the expression "iron and steel" includes alloy steel and stainless steel unless the statute clearly limits it, and a sub-item cannot be used to narrow the scope of the main entry.

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