1991 (9) TMI 340

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.... the application of two notifications granting concession in the rate of tax in respect of the goods involved in these cases. The assessing authority found that the petitioners are not eligible for the concession. On appeal, the decision of the assessing authority was confirmed by the Appellate Assistant Commissioner. Even in the second appeal filed before the Tamil Nadu Sales Tax Appellate Tribunal, the petitioners were unable to convince the Tribunal that they are eligible for the concessional rates granted by the notification. 2.. Before us the learned counsel for the petitioners has placed the notifications and seeks to argue that one or other of the clauses of the notifications will come to the aid of the assessees. Earlier in the yea....

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....ere not handwoven so as to attract the concessional rate provided in the notification. The Tribunal has rendered a factual finding that the assessees manufactured beds and pillows using cloth, both by hand-stitching and machine-stitching. Machine-stitching is done before the stuffing of the cotton waste or silk cotton and hand-stitching is done after the stuffing of the cotton. 4.. In understanding the notification dated November 30, 1962, we have to take note of the subsequent amendment by inclusion of the words "handwoven quilt beds and pillows". A Division Bench of this Court had occasion to consider the import of such amendments. In Associated Agencies v. State of Tamil Nadu represented by the Joint Commissioner II, Office of the Commi....