Classification dispute under sales tax law must be decided on merits, not rejected as a mere rate change request.

A revisional authority under section 55 of the Tamil Nadu General Sales Tax Act, 1959 cannot reject a revision merely by treating a request for correct product classification as an impermissible attempt to alter the tax rate. Where the real dispute concerns whether goods are properly classified as an adhesive or a lubricant, the authority must examine that issue on merits. The rejection orders were therefore set aside, and the revision applications were remitted for fresh consideration. Interim protection against coercive recovery continued until the revisions were disposed of.

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Issues: Whether the revision applications under section 55 of the Tamil Nadu General Sales Tax Act, 1959 could be rejected on the ground that the assessing authority had no power to alter the rate of tax, when the real dispute concerned the correct classification of the product as an adhesive or a lubricant.

Analysis: The prayer in revision was not for a change in the rate of tax simpliciter, but for a determination of the true nature of the product. A revisional authority can examine such a question and decide it on merits. The rejection of the revision applications proceeded on an incorrect understanding of the scope of the revisional power.

Conclusion: The rejection orders were set aside and the revision applications were remitted to the respondent for fresh consideration on merits.

Final Conclusion: The writ petitions succeeded to the extent of securing a reconsideration of the statutory revisions, with interim protection against coercive recovery until disposal of those revisions.

Ratio Decidendi: Where the dispute is about the true classification of goods, the revisional authority cannot decline jurisdiction merely by characterising the relief as an impermissible request to change the rate of tax.

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