1997 (5) TMI 413

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.... May 7, 1994, annexure 3 to the writ petition, petitioners engaged in the manufacture of zipper tapes and zipper laces, were called upon by the assessing authority to show cause why the items manufactured by the petitioners be not brought to tax at the rate of 4 per cent in view of entry 50 of the Notification No. 7036, dated September 29, 1984. 3.. In its representation dated March 3, 1994, an....

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....titioners are engaged in the manufacture of zipper tapes and zipper laces; that tapes and laces manufactured by the petitioners constituted raw material for the manufacture of zippers; that the entire material, namely, tapes and laces manufactured by the petitioners, is being sold only for the manufacture of zippers and for no other purpose; and that the tapes and laces manufactured by the petitio....

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....ing of entry 50 of the Notification No. 7036, dated September 29, 1984 or whether they are used only as raw material for the manufacture of zippers, as averred by the petitioners. 9.. These questions are essentially questions of fact and clear findings have to be recorded on them by the assessing authority. Without findings on these vital questions, it is difficult to reach a correct conclus....