Factual classification of prawns determined tax treatment, with twenty-day-old prawns kept within the Second Schedule entry.

Twenty-day-old prawns were held to fall under entry 19 of the Second Schedule rather than as unclassified goods under the Seventh Schedule. The tribunal's factual finding that the goods sold were prawns, not larvae, was ative, and the higher tax treatment contended for on a larvae classification was rejected. The dispute was treated as one of factual classification, and no question of law arose from the tribunal's order.

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Issues: Whether twenty-day-old prawns were liable to tax as unclassified goods falling under the Seventh Schedule or as prawns under entry 19 of the Second Schedule.

Analysis: The finding recorded by the appellate tribunal was that the goods sold were not larvae but twenty-day-old prawns. On that factual basis, the contention that the products should be treated as larvae and taxed at the higher rate could not be accepted. The dispute turned on the factual classification of the goods, and no question of law arose from the tribunal's order.

Conclusion: The goods were to be treated as prawns under entry 19 of the Second Schedule and not as unclassified goods under the Seventh Schedule. The revision failed.

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