Strict classification in taxing entries keeps dyes under their specific entry, despite use in leather finishing.

Dyes used in leather finishing were treated as a separately classified commodity under Entry 49 of Part C of the First Schedule, rather than being reclassified under Entry 16(iii) of Part E as pigments or leather finishes. The court reasoned that dyes and pigments were distinct products, and that end use in leather finishing did not alter the statutory identity of the commodity. Applying strict construction of taxing entries, it rejected classification by inference or user theory and held that the commodity must fall within the plain language of the specific entry.

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Issues: Whether dyes sold for use in leather finishing fall under Entry 49 of Part C of the First Schedule, or under Entry 16(iii) of Part E of the First Schedule.

Analysis: Dyes were specifically classified as a separate commodity under Entry 49 of Part C, while Entry 16(iii) of Part E referred to pigments including water pigments and leather finishes. The entries treated dyes and pigments as distinct products. The use of dyes in leather finishing did not convert them into pigments, and the expression leather finishes was construed in the context of pigments used in leather finishing, not as a basis to reclassify dyes by reference to user alone. In a taxing statute, the charge must be found strictly within the language of the entry, and no tax can be imposed by inference, analogy, or broad construction. The user theory applied by the lower authorities was therefore rejected.

Conclusion: Dyes remained classifiable under Entry 49 of Part C and were taxable only at 5%.

Ratio Decidendi: Where a taxing entry specifically classifies a commodity, it cannot be reclassified under another entry merely because of the end use of the commodity, and taxing provisions must be construed strictly according to their plain language.

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