1960 (3) TMI 36

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....ree revision cases raise a common question relating to the meaning to be given to the words "goods or silver bullion", occurring in section 6 of the Hyderabad General Sales Tax Act, 1950. T.R.C. No. 91 of 1958 relates to the assessment year 1954-55, T.R.C. No. 92 of 1958 to the year 1955-56 and T.R.C. No. 93 of 1958 to the assessment year 1953-54. The petitioners are a firm of dealers in gold, sil....

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....ful. In these revision cases filed against the order of the Tribunal rejecting the appeals, it is urged by Sri Mallikarjuna Rao that the percussion "gold or silver bullion" is of wide import and takes in gold or silver mixed with base metals like copper or lead. We are unable to accede to this proposition. If really the intention of the Legislature was that every metal which could be described as ....

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....ymous with gold or silver ore before it is refined. It is also worthy of note that the second meaning given in the dictionary also indicates that it is applicable only to pure gold silver. In Wharton's Law Lexicon the following meaning is given: "Bullion is uncoined gold and silver in the mass. Those metals are called so, either when smelted from the native ore and not perfectly refined; or ing....

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....ear that the legislature has used these expressions as containing two different concepts, "bullion" being equated only to pure gold. If the word "bullion" could cover every form of gold or silver, it was unnecessary for the use of the word "specie". Similarly, in the Andhra Pradesh General Sales Tax Act, 1957, the use of the expression "bullion and specie" in items 12 and 13 also is a pointer in t....