Concessional sales tax for rubberised coir products extends to mattresses and pillows made from that material.

The concessional sales tax rate for "rubberised coir products" under G.O. P. No. 303 dated 26.03.1981 was held applicable to rubberised coir mattresses and pillows. The notification used the expression "rubberised coir" without distinguishing between block form and finished products made from that material, and no evidence showed that the goods were predominantly rubber rather than coir. The Revenue's proposed distinction was unsupported by the wording of the notification and could not be accepted at the revision stage, so the tax benefit remained available for the goods in question.

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Issues: Whether the concessional rate of sales tax for "rubberised coir products" under Notification G.O. P. No. 303 dated 26.03.1981 issued under the Tamil Nadu General Sales Tax Act applied to rubberised coir mattresses and pillows.

Analysis: The notification used the expression "rubberised coir" without drawing any distinction between rubberised coir in block form and mattresses or pillows made from such material. No evidence was shown to establish that the impugned products were predominantly rubber as opposed to coir. The Revenue's proposed distinction was therefore unsupported by the wording of the notification and could not be accepted at the revision stage.

Conclusion: The concessional sales tax benefit applied to rubberised coir mattresses and pillows, and the Revenue's challenge failed.

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