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Issues: Whether tin scrap falls within the expression "iron scrap" in clause (iv) of Section 14 of the Central Sales Tax Act and is therefore a declared commodity.
Analysis: Section 14 declares certain goods to be of special importance in inter-State trade or commerce, and Section 15 restricts the State taxing power in respect of such goods. The list in clause (iv) is exhaustive and cannot be enlarged by interpretation. Scrap must be understood in its ordinary and commercial sense as waste or discarded material. Iron and tin are distinct commodities in popular and commercial understanding, and the specific mention of iron scrap, cast iron scrap and iron skull scrap shows that the expression was used in a narrow and popular sense. Tin scrap cannot, therefore, be stretched to mean iron scrap, nor can it be brought within the allied expression relating to defectives, rejects, cuttings or end pieces.
Conclusion: Tin scrap is not iron scrap within clause (iv) of Section 14 of the Central Sales Tax Act and is not a declared commodity.