Declared goods under CST Act exclude stainless steel wire, which cannot be treated as iron and steel for tax restriction purposes.

Stainless steel wire is not covered by the expression "iron and steel" in section 14(iv) of the Central Sales Tax Act, 1956 because the entry is exhaustive and the phrase "of any of the above categories" confines sub-item (ix) to the specified primary goods and raw materials. Although stainless steel may be regarded as an alloy steel in a limited sense, wire is separately recognised as a distinct commercial commodity, so it cannot be read into the declared goods list by implication. It therefore does not attract the section 15 restriction on State tax, and the State levy challenge fails.

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Issues: Whether stainless steel wire is covered by the expression "iron and steel" in section 14(iv) of the Central Sales Tax Act, 1956 so as to attract the restriction on State tax under section 15 of that Act.

Analysis: The statutory entry in section 14(iv) lists specified categories of iron and steel goods in an exhaustive manner. Stainless steel may be treated as an alloy steel and, in that limited sense, as falling within the category of "alloys and special steel". However, the qualifying words "of any of the above categories" restrict sub-item (ix) to the items specifically enumerated in sub-clauses (i) to (viii). Those items are in the nature of primary goods or raw material, whereas wire is separately referred to in sub-clause (xv) as a distinct commercial commodity. Giving full effect to the language used, stainless steel wire cannot be read into sub-item (ix) merely because stainless steel is an alloy steel.

Conclusion: Stainless steel wire is not covered by section 14(iv) of the Central Sales Tax Act, 1956 and is not a declared good for the purpose of section 15. The challenge to the State levy fails.

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