Plausible tax classification cannot be disturbed in revision merely because another view is possible.

Rivets manufactured and sold during the relevant period did not fall within entry 119 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, because that entry then covered bolts, rivets and nuts only in their threaded or tapped form and the later amendment including rivets was not yet operative. The Tribunal's classification treating rivets as permanent fasteners distinct from bolts and nuts was a plausible and reasonable view on the material available, so the revisional court could not interfere merely because another view was possible. Revision was therefore not justified, and the Tribunal's classification was sustained.

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Issues: (i) Whether rivets manufactured and sold by the assessees fell within entry 119 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959. (ii) Whether the revisional court could interfere with the Tribunal's classification merely because another view was possible.

Issue (i): Whether rivets manufactured and sold by the assessees fell within entry 119 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959.

Analysis: Entry 119, as it stood for the relevant period, referred to bolts, rivets and nuts, threaded or tapped, and screws of base metal or alloys thereof. The amendment including rivets was not in force for the period in question. The classification adopted by the Tribunal proceeded on the basis that rivets are permanent fasteners, distinct from bolts and nuts, which are temporary fasteners, and that the qualifying words in the entry indicated articles which were threaded or tapped. The reasoning also treated rivets as separately recognised in trade and technical usage.

Conclusion: Rivets did not fall under entry 119 for the relevant period, and the assessee was not liable to the higher single-point tax on that basis.

Issue (ii): Whether the revisional court could interfere with the Tribunal's classification merely because another view was possible.

Analysis: The Tribunal's view was a possible and reasonable one on the material before it. In revisional jurisdiction, interference is not justified merely because the court may have reached a different conclusion on the same material. Interference is warranted only where the impugned view is so unreasonable that no reasonable person could have taken it.

Conclusion: The revisional court could not substitute its own opinion for that of the Tribunal, and no interference was called for.

Final Conclusion: The classification adopted by the Tribunal was sustained, and the tax revision petitions failed.

Ratio Decidendi: In revision, a plausible classification made by the Tribunal cannot be disturbed merely because another view is possible; interference lies only when the conclusion is unreasonable or perverse.

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