Commodity classification under sales tax law: steel springs fell under the residuary First Schedule entry, not the listed steel categories.

Steel springs were treated as a distinct commercial commodity made from twisted steel wire with hooked ends, and were not covered by the Second Schedule entries for steel bars, sheets, hoops, strips or skelp. Because entry 99/68 of the First Schedule applied to iron and steel articles not mentioned elsewhere in the Schedules, the commodity fell within that residuary-style entry rather than by analogy to listed items. The assessment adopted by the authorities was therefore correct, and steel springs were taxable under entry 99/68 of the Kerala General Sales Tax Act, 1963.

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Issues: Whether steel springs sold by the assessee were classifiable under entry 99/68 of the First Schedule to the Kerala General Sales Tax Act, 1963, or under entry 2(ii)(d) or entry 2(ii)(f) of the Second Schedule.

Analysis: Steel springs were described as a distinct commodity manufactured by twisting steel wire spirally and giving hooked ends, resulting in a commercially different article. The Second Schedule entries relied on by the assessee specifically covered steel bars, sheets, hoops, strips and skelp, but did not include steel springs. Entry 99/68 of the First Schedule covered iron and steel articles not mentioned elsewhere in the Schedules. On that construction, steel springs fell within the First Schedule and not within the Second Schedule entries invoked by the assessee.

Conclusion: The classification adopted by the assessing authority and the appellate authority was correct, and steel springs were liable to be taxed under entry 99/68 of the First Schedule to the Kerala General Sales Tax Act, 1963.

Final Conclusion: The tax revision cases were allowed and the Tribunal's order was set aside, with the questions answered in favour of the Revenue.

Ratio Decidendi: Where a commodity is not specifically mentioned in the more specific schedule entries and is covered by a residuary-style entry for articles not mentioned elsewhere, it must be classified under that entry rather than by analogy to listed items.

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