Specific tariff classification of boards prevailed where the goods were sold as boards, not as waste boards.

Turnover from the sale of boards was held taxable under entry 117 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, because the goods were, in substance and commercial identity, paper board or board falling within that specific entry. The schedule during the assessment year expressly covered paper, paste-board, mill-board, straw board and card board, and the later amendment only broadened the wording further. As the assessee had purchased and sold the goods as boards, there was no factual basis to classify them as waste boards for the general multi-point rate. The revisional authority was therefore justified in restoring the assessment under the specific entry.

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Issues: Whether the turnover from sale of boards was liable to tax under entry 117 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 or at the general multi-point rate on the footing that the goods were only waste boards.

Analysis: The commodity was held to be paper board or board covered by entry 117. The relevant schedule entry during the assessment year specifically included paper, paste-board, mill-board, straw board and card board, and the subsequent amendment only widened the language further. The evidence showed that the assessee had purchased boards and sold them as boards, and there was no factual basis to treat the turnover as sale of waste boards. The appellate authority merely accepted the assessee's assertion without proper supporting material, whereas the revisional authority was justified in restoring the assessment under the specific entry.

Conclusion: The turnover was correctly assessed under entry 117 of the First Schedule and not at the multi-point rate, and the assessee's contention failed.

Ratio Decidendi: Goods are taxable under the specific tariff entry when, in substance and commercial identity, they answer the description in that entry, and an unsupported claim that they were treated as waste does not alter their tax classification.

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