Sales tax classification of projectors upheld where new factual challenge could not be raised for the first time in revision.

Overhead and slide projectors were treated as falling within entry 4 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957, because the material before the revisional authority and the Tribunal, including the manufacturer's leaflet, supported that classification. A fresh factual contention that the projectors could project only still film strips was not specifically pleaded or urged before the Tribunal, and such a new factual issue could not ordinarily be raised for the first time in revision. On the material considered, the Tribunal's classification view was not shown to be erroneous.

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Issues: Whether overhead and slide projectors fall under entry 4 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957, and whether the classification challenge raised for the first time in revision could be entertained.

Analysis: The goods were examined on the basis of the material placed before the revisional authority and the Tribunal, including the manufacturer's leaflet, which supported the view that the projectors were covered by the relevant schedule entry. The challenge that the projector could project only still film strips was a factual contention not specifically pleaded or urged before the Tribunal. A factual issue not raised before the statutory authorities cannot ordinarily be permitted to be raised for the first time in revision. On the material considered, the Tribunal's view that the projectors fell within entry 4 was not shown to be erroneous.

Conclusion: The projectors were held to fall under entry 4 of the First Schedule, and the new factual contention was not entertained.

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