Goods made to customer specifications are not rough cast iron castings; prior year acceptance does not bar later tax appeals.

Goods manufactured to a purchaser's specifications, dimensions and immediate-use requirements were held not to be rough cast iron castings under item 4(i) of the Second Schedule to the Tamil Nadu General Sales Tax Act, 1959, because machining, processing or tailoring to specification takes the goods outside the declared-goods description. The Tribunal's higher-rate assessment was therefore upheld. It was also clarified that each assessment year is a separate unit in tax law, so the Department's acceptance of a view for one year does not bar appeals for later years. The assessee's challenge failed, and the tax treatment sustained.

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Issues: (i) Whether the goods manufactured and supplied by the assessee were rough cast iron castings falling under item 4(i) of the Second Schedule to the Tamil Nadu General Sales Tax Act, 1959, or finished products liable to higher tax. (ii) Whether the Department was barred from filing appeals for later assessment years because it had accepted a contrary view for an earlier year.

Issue (i): Whether the goods manufactured and supplied by the assessee were rough cast iron castings falling under item 4(i) of the Second Schedule to the Tamil Nadu General Sales Tax Act, 1959, or finished products liable to higher tax.

Analysis: The materials showed that the goods were manufactured to the purchaser's specifications, dimensions, and measurements, and were supplied for immediate use in the customers' manufacturing process. The invoices and form records described the items as specific components and pattern equipment rather than mere rough castings. On the settled distinction between rough cast iron castings and processed finished goods, goods subjected to machining, polishing, or manufacture to customer specifications cease to answer the description of cast iron castings or declared goods.

Conclusion: The goods were not rough cast iron castings within item 4(i) of the Second Schedule and were rightly assessed at the higher rate; the finding of the Tribunal was upheld.

Issue (ii): Whether the Department was barred from filing appeals for later assessment years because it had accepted a contrary view for an earlier year.

Analysis: Each assessment year is a separate unit in tax law, and acceptance of an order for one year does not prevent the State from challenging assessments for another year. A prior non-appeal does not create a bar against appeal in subsequent years.

Conclusion: The contention of departmental bar based on earlier acceptance was rejected.

Final Conclusion: The challenge to the Tribunal's order failed in its entirety, and the tax treatment adopted against the assessee was sustained.

Ratio Decidendi: Goods manufactured to the purchaser's specifications for immediate use, and not merely in rough cast form, are not to be treated as cast iron castings or declared goods for sales tax classification purposes; acceptance of a view for one assessment year does not fetter the State's right to contest another year.

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