PVC sheets not covered by plastic articles entry; higher single-point sales tax rate could not apply without express inclusion.

PVC sheets were held not to fall under entry 145 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 because the entry had to specifically cover the goods before the 8 per cent single-point levy could apply. The later amendment excluding PVC conduit pipes and fittings from the plastic articles entry was treated as significant, and the absence of any express reference to PVC sheets meant they were not brought within the higher rate. The classification at 4 per cent multi-point was therefore upheld, with the assessee succeeding.

---

---

Issues: Whether PVC sheets fall under entry 145 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 so as to attract tax at 8 per cent single point.

Analysis: Entry 145 originally referred to plastic articles. The later amendment from 3 June 1981 expressly excluded PVC conduit pipes and fittings, but did not mention PVC sheets. The omission was treated as significant, and it was held that an item cannot be subjected to single-point levy unless it is specifically mentioned in the First Schedule. The reasoning also drew support from the principle that the schedule entry must clearly cover the goods before the higher single-point rate can be applied.

Conclusion: PVC sheets do not fall under entry 145 of the First Schedule and are not liable to tax at 8 per cent single point. The revised classification at 4 per cent multi-point was upheld, and the assessee succeeded.

---