Dyed yarn remains yarn for tax purposes, so reassessment based on a rejected commodity distinction could not stand.

Dyed yarn retained its character as yarn for tax purposes; adding colour or selling it as sewing thread did not create a different commodity. Because the reassessment was reopened solely on a view later disapproved by binding precedent, the revised assessment had no sustainable basis. The reassessment orders were therefore unsustainable and the challenge succeeded.

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Issues: Whether the impugned reassessment could survive in view of the binding decision holding that dyed yarn continues to retain its character as yarn and cannot be treated as a different commodity for tax purposes.

Analysis: The assessment had been reopened solely on the basis of an earlier view that was later disapproved. The governing precedent held that dyeing and selling the yarn as sewing thread did not change its essential character, and the addition of colour did not make it any less yarn. Once that basis was no longer sustainable, the proposed revision of assessment could not stand.

Conclusion: The challenge succeeded and the reassessment orders were unsustainable.

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