STATE OF KERALA Vs. DECCAN INDUSTRIES

JUDGEMENT

(1.) These Tax Revision Cases have been preferred by the State of Kerala raising the following questions of law, which are extracted hereunder:

(2.) Before examining the scope of entry 99/68 of the First Schedule to the Kerala General Sales Tax Act and Entry 2(ii)(d) and 2(ii) (f) of the Second Schedule to the Act, we may first examine the meaning and ambit of the words "steel spring" and how it is manufactured. Steel wire of specified SWG is twisted spirally by means of mechanical process of required lengths, normally varying from 9 to 25 inches and 3 1/2 to 7 inches in diameter and both the ends of the spirally twisted spring are heated and forming hooked ends so as to enable to fasten with the wheel connected with the axle of the rolling shutter and due to this manufacturing process a commercially different commodity made of steel emerges. Dictionary meaning of the spring is also relevant. We may refer to the meaning given by New Websters' Dictionary of English, which is extracted below: