Classification findings of the final fact-finder cannot be disturbed without new material or legal error in evidence assessment.

Gelatine was held not to fall within the description of a chemical under Entry 138 of the Tamil Nadu General Sales Tax Act, 1959, because the Tribunal as final fact-finding authority had found it to be a natural product without a definite chemical formula. The High Court should not have disturbed that classification finding in the absence of any additional material from the Revenue or any showing that the Tribunal's view was unsupported by evidence, based on irrelevant evidence, or founded on an incorrect principle. The Revenue's classification was therefore unsustainable and the assessee succeeded.

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Issues: Whether gelatine fell within the description of a chemical under Entry 138 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959.

Analysis: The Tribunal, as the final fact-finding authority, had examined expert opinions and other materials and concluded that gelatine was a natural product without a definite chemical formula and did not answer the description of a chemical. The High Court reversed that finding without any additional material being produced by the Revenue and without finding that the Tribunal's view was unsupported by evidence, based on irrelevant evidence, or founded on incorrect principles. A factual finding of the final fact-finding authority was not liable to be ignored in such circumstances.

Conclusion: Gelatine was not a chemical for the purpose of Entry 138, and the Revenue's classification was unsustainable; the decision is in favour of the assessee.

Ratio Decidendi: A High Court should not disturb a final fact-finding authority's conclusion on classification unless the finding is shown to be based on no evidence, irrelevant evidence, or an incorrect principle, especially where no additional material is produced to justify departure from that finding.

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