Classification of iron and steel goods: high mast poles were held to fall under the specific VAT entry, not the residuary entry.

High mast iron poles and accessories manufactured from hot rolled sheets by cutting, bending, welding, straightening and galvanization remained commercially identifiable as iron and steel products. The Court applied the settled rule that pipes and tubes do not lose their character merely because they are used to make poles, and that a residuary VAT entry can be used only when no specific entry covers the goods on a liberal construction. The goods were therefore classified under the specific entry for iron and steel, including steel tubes and related fittings, and not under the residuary entry, with tax liability determined accordingly in favour of the assessee.

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Issues: Whether high mast iron poles and accessories are classifiable under the specific entry for iron and steel or pipes, or under the residuary entry for VAT purposes.

Analysis: The goods were manufactured from hot rolled sheets by cutting, bending, welding, straightening and galvanization, and were found to remain iron and steel products. The Court relied on the principle that pipes and tubes used to make poles do not cease to be pipes and tubes merely because they are put to a different use. It also applied the settled rule that a residuary entry can be invoked only when the specific entry cannot cover the goods by a liberal construction. The goods were held to fit within the entry for iron and steel, including steel tubes and related fittings, rather than the residuary entry.

Conclusion: The classification under the residuary entry was rejected. The goods were held to fall under the specific VAT entry for iron and steel and were liable to be taxed accordingly, in favour of the assessee.

Ratio Decidendi: Where manufactured goods remain commercially identifiable as iron and steel products or pipes and tubes, they must be classified under the specific entry covering those goods, and the residuary entry cannot be applied.

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