Copper wire exemption turns on essential character; enamelling and insulation did not change its status as copper product.

Copper wire that is merely enamelled and insulated may retain its character as a product of copper for exemption purposes where copper is used as the raw material in Rajasthan. The commentary notes that the finished goods were sold as copper wire for meter use, and the added enamelling and insulation did not alter their essential nature. It also states that, where the nature of the product has been concurrently found on evidence by the lower authorities, revisional interference is not warranted absent a substantial question of law. The exemption was therefore upheld and the concurrent factual findings were left undisturbed.

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Issues: (i) Whether super enameled copper wire and insulated copper wire manufactured from copper purchased on concessional rate remained a product of copper so as to qualify for the exemption under the notification dated 06.03.1991. (ii) Whether the High Court should interfere in revisional jurisdiction with concurrent findings of fact recorded by the appellate authority and the Tax Board.

Issue (i): Whether super enameled copper wire and insulated copper wire manufactured from copper purchased on concessional rate remained a product of copper so as to qualify for the exemption under the notification dated 06.03.1991.

Analysis: The notification exempted sale of any product of copper where copper was used as raw material in the manufacture of another product of copper within Rajasthan. The assessee purchased copper wire, subjected it to enameling and insulation, and sold the finished goods as copper wire for use in meters. The mere addition of enameling and insulation did not change the essential character of the goods. The product continued to be a copper product, and the description used in the firm name could not alter that legal character.

Conclusion: The finished goods remained a product of copper and were entitled to the exemption; this issue was decided in favour of the assessee.

Issue (ii): Whether the High Court should interfere in revisional jurisdiction with concurrent findings of fact recorded by the appellate authority and the Tax Board.

Analysis: The nature of the product was treated as a question of fact, and both subordinate authorities had reached the same conclusion on the evidence. In the absence of any substantial question of law, revisional interference was not warranted.

Conclusion: No interference was called for in revisional jurisdiction; this issue was against the Revenue.

Final Conclusion: The exemption was upheld and the Revenue's challenge failed, leaving the concurrent factual findings undisturbed.

Ratio Decidendi: Where the essential character of a manufactured item remains that of the exempted raw material product, and the issue is conclusively determined as a question of fact by subordinate authorities, the revisional court will not interfere absent a substantial question of law.

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