Tea chest battens fall outside the tea chest entry and are taxable as general goods.

Tea chest battens were not covered by entry 96 of the Kerala General Sales Tax Act as "tea chests" because the entry, read with its explanation, extended only to planks and panels that formed the chest when assembled. The classification therefore depended on the goods being a finished tea chest rather than component battens. On that construction, the goods were taxable as general goods at the rate applicable outside the specific tea chest entry, and the clarification in the assessee's own case was accepted as correctly resolving the issue.

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Issues: Whether tea chest battens fall within entry 96 of the First Schedule to the Kerala General Sales Tax Act, 1963 as "tea chests", or are taxable as general goods.

Analysis: Entry 96 covered "tea chests", and its explanation extended the entry to planks and panels only when they formed the chest when assembled. The Board of Revenue had clarified in the assessee's own case that sale of battens, even if capable of being treated as planks, did not amount to sale of tea chests. That clarification was accepted as correctly resolving the classification issue.

Conclusion: Tea chest battens do not fall under entry 96 as tea chests and are taxable at 4 per cent as general goods, in favour of the assessee.

Final Conclusion: The revisions were allowed on the classification issue, and the goods were held taxable only at the general rate applicable to goods outside the specific tea chest entry.

Ratio Decidendi: Where a tariff or sales tax entry covers a finished article, components or materials do not fall within that entry unless the statutory language or explanation expressly brings them within it.

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