Cotton fabric classification under sales tax entry follows the incorporated excise definition, preserving exemption for processed tarpaulin.

A State sales tax entry that expressly adopts the Central Excise definition of "cotton fabrics" must be applied by reference to that incorporated definition, not by a broader common parlance test. Tarpaulin made from processed cotton canvas, though cut, stitched at the edges and fitted with eyelets, retained its essential character as cotton fabric and fell within the substituted entry 4 of the Third Schedule to the Tamil Nadu General Sales Tax Act, 1959. The classification therefore attracted the statutory exemption, and earlier decisions on the unamended reference to "textiles" did not control the amended entry.

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Issues: Whether tarpaulin manufactured from processed cotton canvas by cutting, stitching the edges and providing eyelets is classifiable as "cotton fabrics" under entry 4 of the Third Schedule to the Tamil Nadu General Sales Tax Act, 1959 and therefore exempt from tax.

Analysis: The substituted entry 4 in the Third Schedule, introduced with effect from 1 April 1974, refers to "cotton fabrics" as defined in item 19 of the First Schedule to the Central Excises and Salt Act, 1944. The legislative object of the amendment was to align the State exemption with the central excise definition. Tarpaulin, as sold by the assessee, was treated in the relevant excise and sales tax decisions as falling within item 19 of the Central Excise Tariff. The fact that the canvas was cut, stitched and fitted with eyelets did not change its essential character for classification. The earlier decisions on the unamended entry dealing with the general term "textiles" did not govern the substituted entry, which specifically incorporated the central excise definition.

Conclusion: Tarpaulin is cotton fabrics within the substituted entry 4 of the Third Schedule to the Tamil Nadu General Sales Tax Act, 1959 and the assessee was entitled to exemption.

Final Conclusion: The revisions failed because the finished product sold by the assessee was held to fall within the exempted classification under the amended sales tax entry.

Ratio Decidendi: Where a State sales tax entry expressly adopts the definition of a commodity from the Central Excise tariff, the classification must follow that incorporated definition and not a broader common parlance understanding; a processed fabric retaining its essential character remains within the exempted category despite cutting, stitching or fitting.

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