Incorporation by reference in tax law can carry later amendments where related statutes work together and avoid unworkable results.

The exemption entry in the Kerala General Sales Tax Act was linked to the definition of "cotton fabrics" in the Central Excises and Salt Act, and the Court applied the distinction between mere reference and incorporation by reference. It held that, where the taxing enactments were supplemental and coordinated, later amendments to the parent excise definition could be read into the sales tax provision if a static reading would make the later Act unworkable or ineffective. The broadened excise meaning of "cotton fabrics" therefore governed the exemption entry, and the refund claim had to be reconsidered on that basis.

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Issues: Whether the amended definition of "cotton fabrics" in the Central Excises and Salt Act, 1944, stood incorporated into the Kerala General Sales Tax Act, 1963 for determining exemption from sales tax on PVC cloth.

Analysis: The exemption entry in the Kerala General Sales Tax Act linked the taxable entry to the definition of "cotton fabrics" in the Central Excises and Salt Act, 1944. The statutory scheme of the Central Sales Tax Act, the Additional Duties of Excise (Goods of Special Importance) Act, 1957, and the Kerala sales tax enactment showed that the goods of special importance were intended to operate in a coordinated manner. The Court applied the settled distinction between a mere reference and incorporation by reference, and held that even where a provision is incorporated, subsequent developments in the parent statute may still be read into the later Act where the two enactments are supplemental to each other or where excluding the later amendment would make the later Act unworkable and ineffectual. On that approach, the broadened meaning of "cotton fabrics" under the Central excise law could not be ignored in the sales tax schedule.

Conclusion: The amended excise definition applied to the sales tax exemption entry, and the assessee was entitled to have the claim for refund reconsidered in the light of that construction.

Final Conclusion: The tax revisions were allowed and the matters were sent back for determination of the refund due, if any, on the basis that the expanded statutory meaning of "cotton fabrics" governed the exemption.

Ratio Decidendi: Where a later taxing statute incorporates or refers to a definition in another enactment, subsequent amendments to the parent enactment may be carried into the later statute when the enactments are supplemental to each other or when a static construction would render the later statute ineffective or unworkable.

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