Declared goods classification for stainless steel wire turns on statutory description, not end use, excluding residuary taxation.

Stainless steel wire used for resistance purposes was treated as declared goods under section 14(iv)(xv) of the Central Sales Tax Act, 1956, because classification depended on the statutory description of the commodity and not its end use. The Court applied the principle that a residuary entry can be used only when the goods do not reasonably fit a specific entry, and held that wire does not cease to be wire merely because it is later used for resistance purposes. On the materials, the Revenue did not displace the claim that the goods fell within the specific declared-goods entry, so the residuary tax entry was inapplicable.

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Issues: Whether stainless steel wire used for resistance purposes was covered by section 14(iv)(xv) of the Central Sales Tax Act, 1956 as declared goods, or whether it fell within the residuary entry attracting a higher rate of tax under the West Bengal Sales Tax Act, 1994.

Analysis: The determining question was one of classification. The goods were shown to be stainless steel wire imported and assessed as such by customs, and the Court held that the description did not cease to be wire merely because it was later used for resistance purposes. The expression in section 14(iv)(xv) covering wire rods and wires was to be read with the main legislative entry on iron and steel, and the sub-item could not be narrowed by treating a particular end use as decisive. The Court also applied the settled principle that a residuary entry can be invoked only when the goods cannot reasonably fall within a specific entry. On the materials, the Revenue had not displaced the claim that the goods were specific declared goods.

Conclusion: Stainless steel wire resistance was held to be covered by section 14(iv)(xv) of the Central Sales Tax Act, 1956 and not by the residuary tax entry.

Ratio Decidendi: A commodity falling within a specific declared-goods entry cannot be shifted to a residuary entry merely because of its end use, and classification must be made by the statutory description read as a whole, with the burden on the Revenue to prove exclusion from the specific entry.

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