Classification of galvanised and corrugated iron sheets turns on essential identity, which remained unchanged for sales tax purposes.

Galvanised plain and corrugated iron sheets remained classifiable within the relevant sales tax entries for iron and steel because galvanisation was only a protective process that made the sheets weather-proof and rust-proof without changing their essential identity, structure, or function. Corrugation likewise did not take the goods outside the description of iron and steel, since shaping iron into sheets and corrugating them did not alter the commodity's core character. The Tribunal was therefore incorrect in excluding these goods from the tariff entries, and classification was held in favour of the assessee and against the department.

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Issues: Whether galvanised plain and corrugated iron sheets fell within entry 3 in Schedule B, Part I to the Bombay Sales Tax Act, 1959 and entry 3 in Schedule II, Part A to the Gujarat Sales Tax Act, 1969.

Analysis: Galvanisation was treated as a protective process that made iron sheets weather-proof and rust-proof without changing their structure or function, so the commodity remained the same. Corrugation of iron sheets was also held not to take the goods out of the description of iron and steel, as shaping iron into sheets and corrugating them did not change the essential identity of the commodity.

Conclusion: The Tribunal was not right in excluding galvanised plain and corrugated iron sheets from the relevant tariff entries, and the question was answered in the negative in favour of the assessee and against the department.

Ratio Decidendi: A process that does not change the essential identity, structure, or function of iron goods does not alter their classification under the sales tax entry for iron and steel.

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