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Issues: Whether Novopan plywood used in the manufacture of doors and windows was classifiable under Entry 114 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957, or as unclassified goods for the assessment year 1987-88.
Analysis: The classification had to be tested with reference to the law applicable to the relevant assessment year. The words "in any other form including flush doors" were introduced into Entry 114 only by the Andhra Pradesh General Sales Tax (Amendment) Act, 1989, with effect from 15 February 1989. Since that amendment was not in force during the assessment year in question, the expanded wording could not be applied retrospectively to bring the commodity within Entry 114.
Conclusion: The commodity was not taxable under Entry 114 for the assessment year 1987-88 and remained outside that entry.
Final Conclusion: The revision failed and the classification adopted by the Tribunal was left undisturbed.
Ratio Decidendi: A commodity cannot be brought within a taxing entry on the basis of words introduced into that entry by a subsequent amendment unless the amendment is operative for the relevant assessment period.