Rubberised coir classification upheld as coir products, not foam rubber, for sales tax purposes.

Rubberised coir mattresses and pillows made from coir fibre, latex gum and polyurethane foam were treated as rubberised coir products rather than foam rubber products for sales tax classification. The appellate authority and Tribunal, after examining the samples and manufacturing materials, found that the use of latex gum to bind the coir fibre did not alter the character of the goods. Relying on the relevant schedule entry and earlier judicial treatment of rubberised coir products, the classification under Item 24 of Part C of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 at 5% was upheld, and the Revenue's challenge failed because no substantial question of law arose.

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Issues: Whether rubberised coir products, including mattresses and pillows manufactured using coir fibre, latex gum and polyurethane foam, were classifiable under Item 24 of Part C of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 at 5% or under Item 15 of Part E at 12%.

Analysis: The appellate authority and the Tribunal concurrently found, on examination of the samples and manufacturing materials, that the goods were rubberised coir products and not foam rubber products. They held that the mere use of latex gum in binding coir fibre did not change the character of the product, and relied on the relevant schedule entry and the earlier judicial view treating rubberised coir products as falling within Item 24 of Part C. The Court found no strong material to disturb these concurrent factual findings and held that no substantial question of law arose for interference.

Conclusion: The classification under Item 24 of Part C at 5% was upheld and the challenge by the Revenue failed.

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