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1987 (4) TMI 450

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....of the assessee. The only question for decision is, whether the Board of Revenue has rightly held that the dressed sheets of hides/skins consisting of leather clippings used as soles in footwear were taxable under entry No. 12 and not entry No. 36 of the Notification No. F. 5(16)FD(CT)/69-2 dated 8th March, 1969. The contention of the department reiterated in this revision is that these goods are ....

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.... said to be used as soles in footwear. Even assuming that the goods can be treated as leather goods, which in my opinion it cannot, it would form a part of the footwear, and footwear being expressly excluded from entry No. 36, the same cannot be treated as covered by entry No. 36. As compared to entry No. 36, it is clear that entry No. 12 is more appropriate for the goods in question, and, therefo....