Tariff classification governs sales tax exemption: printed cloth labels fall under the specific labels heading, not narrow woven fabrics.

Printed cloth labels were held outside the sales tax exemption for narrow woven fabrics under Entry 11, Part A of the Third Schedule to the Tamil Nadu General Sales Tax Act, 1959. The entry had to be read with Heading 5806 of the Central Excise Tariff, which covers narrow woven fabrics, but the goods were specifically classifiable under Heading 5807 as labels and similar textile articles. Because a specific tariff classification prevailed over the general description, the labels could not be treated as exempt narrow woven fabrics. A departmental clarification could not expand the scope of the statutory entry beyond its text, so the exemption claim failed and taxability was upheld.

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Issues: Whether printed cloth labels or woven labels were classifiable under Entry 11, Part A of the Third Schedule to the Tamil Nadu General Sales Tax Act, 1959 and thus entitled to exemption from sales tax.

Analysis: Entry 11 of Part A of the Third Schedule refers to narrow woven fabrics as described against Heading 5806 of the First Schedule to the Central Excise Tariff Act, 1985. The scope of the exemption therefore had to be tested by reading Heading 5806 along with the related tariff scheme. Heading 5806 covers narrow woven fabrics other than goods of Heading 5807, while Heading 5807 specifically covers labels, badges and similar articles of textile materials, in the piece, in strips or cut to shape or size, not embroidered. As the assessee's goods were printed cloth labels, they fell within the specific exclusionary classification under Heading 5807 and could not be brought within the exemption entry by treating them as narrow woven fabrics. A departmental clarification could not enlarge the statutory entry beyond its text.

Conclusion: The assessee was not entitled to exemption under Entry 11, Part A of the Third Schedule.

Final Conclusion: The taxability of the goods was upheld, the exemption claim failed, and the assessment was restored, with the revision succeeding only to the extent of the tax demand.

Ratio Decidendi: Where a fiscal exemption entry is linked to a specific tariff heading, goods specifically covered by another tariff heading cannot be brought within the exemption by treating them as a general description of narrow woven fabrics.

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