Plastic-based vinyl tiles classified as articles made of plastic, excluding the residuary tiles entry under the Karnataka sales tax schedule.

Plastic-based marblex vinyl tiles are covered by the specific wording of Entry No. 110 in the Karnataka Sales Tax Act, which extends to articles made of plastic, polythene or poly-vinyl chloride material. Entry No. 182, dealing with floor, wall and roofing tiles, applies only where no other entry covers the goods, so it cannot override the specific plastic entry. The classification therefore falls under Entry No. 110 and not Entry No. 182, with the assessee succeeding on revision.

---

---

Issues: Whether marblex vinyl tiles and similar plastic-based tiles fall under Entry No. 110 of the Second Schedule to the Karnataka Sales Tax Act, 1957 as articles made of plastic, or under Entry No. 182 as floor, wall and roofing tiles not covered by any other entry.

Analysis: Entry No. 110 expressly covers plastic sheets and all articles made of plastic, polythene or poly-vinyl chloride material. The article in question was found to be a plastic-based product and therefore within the breadth of that entry. Entry No. 182 applies only to floor, wall and roofing tiles that are not covered by any other entry, so once the goods are brought within Entry No. 110, Entry No. 182 stands excluded. The principle applied was that effect must be given to the specific language of the entry covering articles made of plastic, and the residuary wording in the tiles entry cannot displace it.

Conclusion: The goods are classifiable under Entry No. 110 and are not taxable under Entry No. 182. The revision succeeded in favour of the assessee.

---