Declared goods in works contracts remain taxable on incorporation, and no substantial question of law arose.

Iron and steel used in a works contract, when merely cut, bent, tied, or otherwise incorporated without losing their identity as declared goods, remain taxable as declared goods subject to the constitutional and statutory limits under Article 286(3) and Section 15 of the Central Sales Tax Act. The Tribunal correctly applied the settled principle that tax attaches on incorporation in the works contract, and the Supreme Court had already affirmed that position. As the controversy was fully covered by existing law, no substantial question of law survived for interference, and the revenue challenge failed.

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Issues: Whether iron and steel used in the execution of a works contract, which retain their identity as declared goods, can be subjected to tax at 4%; and whether any substantial question of law arose warranting interference with the Tribunal's order.

Analysis: The Tribunal had followed the settled legal position that iron and steel used in works contract, when merely cut, bent, tied, or otherwise incorporated without transformation into a new commercial commodity, continue to be declared goods. The governing principle, as affirmed by the Supreme Court, is that goods transferred in a works contract are taxable at the point of incorporation, subject to the constitutional restrictions under Article 286(3) of the Constitution of India and the statutory restrictions in Section 15 of the Central Sales Tax Act, 1956. Since the Supreme Court had already affirmed the legal position relied on by the Tribunal, the High Court held that the controversy stood covered and no question of law survived.

Conclusion: The challenge by the revenue failed, and the Tribunal's view on taxability of iron and steel at 4% was left undisturbed.

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