{"id":46455,"date":"1989-02-03T00:00:00","date_gmt":"1989-02-02T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/state-of-tamil-nadu-vs-mahi-traders-ors-etc-etc-on-3-february-1989"},"modified":"2016-03-02T22:32:08","modified_gmt":"2016-03-02T17:02:08","slug":"state-of-tamil-nadu-vs-mahi-traders-ors-etc-etc-on-3-february-1989","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/state-of-tamil-nadu-vs-mahi-traders-ors-etc-etc-on-3-february-1989","title":{"rendered":"State Of Tamil Nadu vs Mahi Traders & Ors. Etc. Etc on 3 February, 1989"},"content":{"rendered":"
Supreme Court of India<\/div>\n
State Of Tamil Nadu vs Mahi Traders & Ors. Etc. Etc on 3 February, 1989<\/div>\n
Equivalent citations: 1989 AIR 1167, \t\t 1989 SCR (1) 445<\/div>\n
Author: S Rangnathan<\/div>\n
Bench: Rangnathan, S.<\/div>\n
           PETITIONER:\nSTATE OF TAMIL NADU\n\n\tVs.\n\nRESPONDENT:\nMAHI TRADERS & ORS. ETC. ETC.\n\nDATE OF JUDGMENT03\/02\/1989\n\nBENCH:\nRANGNATHAN, S.\nBENCH:\nRANGNATHAN, S.\nMUKHARJI, SABYASACHI (J)\n\nCITATION:\n 1989 AIR 1167\t\t  1989 SCR  (1) 445\n 1989 SCC  (1) 724\t  JT 1989 (1)\t196\n 1989 SCALE  (1)267\n\n\nACT:\n    Central  Sales  Tax\t Act, 1956:  Sections  14(1)(iii)  &\n15--'Leather splits', 'Coloured leather'--Whether hides\t and\nskins--Eligibility for special treatment under the Act.\n    Statutory\t\t       construction--Contemporaneous\nexposition--Opinion rendered on meaning of statutory expres-\nsions by the Department concerned--The terms of the  statute\ncan  be\t construed by reference to such\t exposition--In\t the\nabsence of anything in the statute to indicate the contrary.\nWords & phrases: 'Leather splits'--Meaning of.\n\n\n\nHEADNOTE:\n    The\t respondents  are dealers in hides and\tskins.\tThey\ndeal among other things in splits and coloured leather.\t The\nsplits are the cut pieces, small and irregular, obtained  in\nthe process of cutting raw or tanned hides and skins  either\nwith  a\t view to reduce their thickness or to  give  them  a\nregular shape. Coloured leather is obtained when the  tanned\nhides and skins are dyed with various colours. The claim  of\nthe respondents is that these two items fail in the list  of\n\"goods\tof special importance in inter-State trade and\tcom-\nmerce\"\tset out in s. 14 of the Central Sales Tax  Act\tand,\ntherefore, entitled to the concessions available under s. 15\nof the Act, namely the benefits of single point taxation and\nof  a smaller rate of tax. Such claims were allowed  by\t the\nassessing  authority in respect of coloured leather  and  in\nrespect\t of splits he disallowed the claims.  The  Appellate\nAssistant  Commissioner\t upheld the order of  the  assessing\nauthority.  The Board of Revenue negativated the  contention\nthat  leather  splits continued to be  dressed\tskins  under\ndeclared goods of inter-State importance and held that these\nsplits\tare to be treated as 'scraps' or to be taxed at\t the\nmultiple  rates. As regards coloured leather the Board\theld\nthat these are commercially different products and that\t the\nexemption granted was not correct. The tribunal, in  certain\ncases,\thad held that the assessee was entitled to the\tcon-\ncessions claimed in respect of both items.\nThe  respondents moved the High Court by way of\t Writ  Peti-\ntions\n446\nand  tax revision cases and the High Court upheld the  claim\nof  the\t respondents, holding that  'splits'  and  'coloured\nleather' continue to be hides and skins eligible for special\ntreatment under the Central Sales Tax Act.\n    The\t present appeals by special leave are against  those\njudgments of the High Court.\n    The\t contentions  of the appellant-State were  that\t the\nleather\t splits or cuttings are \"scrap\" and do\tnot  qualify\nany  longer  to be described merely as hides and  skins\t and\nthat  coloured\tleather is a totally new  and  sophisticated\nproduct\t known\tas leather and can no  longer  be  described\nmerely\tas  hides and skins and as such cannot\tqualify\t for\nexemption.\n    On\tbehalf of the respondents, a reference was  made  to\ncertain circulars of the authorities which contain a contem-\nporaneous exposition of the meaning of the entry in question\nand contended that, to say that one item being called scraps\nand  the  other as leather would not be sufficient  to\ttake\nthem  out of the description \"hides and skins, in a  raw  or\ndressed\t state\"\t and cuttings of hides and skins  would\t not\ncease  to be hides and skins merely because they  are  small\npieces\tand  can be loosely described as  \"scraps\".  As\t for\ncoloured  leather, it was contended that the exact scope  of\nthe  expression\t used in entry (iii) of s. 14(1)  which\t re-\nferred\tto  'hides  and skins whether in a  raw\t or  dressed\nstate' would have to be looked into.\nDismissing the appeals,\n    HELD:  1.1.\t The High Court was right  in  holding\tthat\n'splits'  and  'coloured leather' continue to be  hides\t and\nskins eligible for special treatment under the Central Sales\nTax Act. [456E]\n    1.2\t A contemporaneous exposition by the  administrative\nauthorities  is\t a  very useful and relevant  guide  to\t the\ninterpretation of the expressions used in a statute. Consid-\nering that the clarification was sought for from the  Minis-\ntry  of Commerce at the earliest point of time when a  doubt\narose as to the scope of the expression used by the  statute\nand given after considering the technicalities of the  proc-\nesses employed in the manufacture of finished leather by the\ndepartment fully conversant with this branch of trade and in\nthe  context  of the provisions of this\t very  statute,\t the\nterms  of the statute can well be construed by reference  to\nsuch  exposition, in the absence of anything in the  statute\nto indicate the contrary. Indeed, such interpretation should\nbe shown to\n447\nbe  clearly wrong before it is overturned. The view  of\t the\nMinistry was that the expression 'hides and skins in the raw\nor  dressed  State' refers at one end to  the  raw  material\nobtained  from\tthe slaughtered or dead animals and  at\t the\nother  end to the tanned and finished material; the  expres-\nsion,  therefore,  seems to include the\t other\tintermediate\nstages\tas well. 'Dressing' according to  the  authoritative\ninterpretations,  would mean the conversion of tanned  hides\nand  skins by further suitable processing into\tleathers  of\ndifferent types which are ready for use. [452F-H; 452B-D]\n    Desh  Bandhu  Gupta and Ors. v.  Delhi  Stock  Exchange,<\/a>\n[1979]\t4 SCC 565; Verghese v. I.T.O., [1981] 131  ITR\t597,\nrelied on.\n    Mahi Traders v. State of Tamil Nadu, [1980] 45 STC\t327,\napproved.\n    2. Definitions in this regard show that hides and  skins\nacquire\t the name of 'leather' even if the hair or wool\t has\nnot  been  removed therefrom, as soon as they  receive\tsome\ntreatment which prevents them from putrefaction after treat-\nment  with  water.  'Dressing' is a stage  much\t later\tthan\ntanning. Indeed, from the definitions it is clear that it is\npractically  the  same as giving finishing  touches  to\t the\nleather\t and making it suitable for the manufacture of\tpar-\nticular types of goods. The findings of the Tribunal in this\nregard\tin  an\tearlier case, which had\t not  been  appealed\nagainst by the Department, that under the Central Sales\t Tax\nAct, the appellant is in a much better position, because all\nthe  hides and skins are brought together in one entry,\t and\nwhether\t raw  or dressed, the product falls under  the\tsame\nentry,\tseems  to be the correct view of the  scope  of\t the\nentry in question. [454B-D; 455E]\n    Glossary  of terms relating to hides, skins and  leather\npublished by ISI in 1960: Dictionary of Leather\t Terminology\npublished  by the Tanners' Council of America.\tEncyclopedia\nBritannica Vol. 7 and, 'Wealth of India'. Part V, a publica-\ntion  of the Council of Scientific and Industrial  Research,\n1966, relied on.\n    3. Hides and skins are termed 'leather' even as soon  as\nthe  process  of  tanning is over and the  danger  of  their\nputrefaction  is  put an end to. The entry  in\tthe  Central\nSales Tax Act, however, includes within its scope hides\t and\nskins  until they are 'dressed'. This represents  the  stage\nwhen they undergo the process of finishing and assume a form\nin  which  they can be readily utilised for  manufacture  of\nvarious\t commercial  articles. In this view,  it  is  hardly\nmaterial  that coloured leather may be a form of leather  or\nmay even be said to represent a different commer-\n448\ncial commodity. The statutory entry is comprehensive  enough\nto include the products emerging from hides and skins  until\nthe process of dressing or finishing is done. [456C-E]\n\n\n\nJUDGMENT:\n<\/pre>\n
    CIVIL APPELLATE JURISDICTION: Civil Appeal Nos.  2665-72
\n(NT) of 1981 etc. etc.
\n    From the Judgment and Order dated 9.1.1980 of the Madras
\nHigh Court in Tax Case Nos. 894, 895 of 1977, 591,  942,968,
\n975 of 1979 and W.P. Nos. 4951 and 4952 of 1978.
\n    S. Padmanabhan, R. Mohan and R.A. Perumal for the Appel-
\nlant.\n<\/p>\n
    T.A.  Ramachandran,\t A.K.  Sen,  Mrs.  J.  Ramachandran,
\nInbarajan,  P.N. Ramalingam, A.T.M. Sampath and A.V.V.\tNair
\nfor the Respondents.\n<\/p>\n
The Judgment of the Court was delivered by
\n    RANGANATHAN,  J.  All these civil  appeals\tand  special
\nleave petitions raise a common question as to the  interpre-
\ntation\tof an expression used in the Central Sales Tax\tAct.
\nSome  of  these matters arise out of judgments of  the\tHigh
\nCourt  in  Tax Revision cases and some out of  judgments  in
\nwrit  petitions but the point involved is the same. 1n\tview
\nof  the pendency of the appeals, we grant leave in the\tspe-
\ncial  leave  petitions after condoning the delay  in  filing
\nsome of them and proceed to dispose of all the appeals by  a
\ncommon order.\n<\/p>\n
    The\t respondents  are  all dealers in  hides  and  skins
\ncarrying on business in the State of Tamil Nadu. As is\twell
\nknown, raw hides and skins undergo various processes such as
\ncutting, tanning, dyeing, dressing and finishing before they
\nget  converted into finished leather and assume a  condition
\nfit  for the manufacture of various kinds of  leather  arti-
\ncles. The dispute in these appeals is in regard to two items
\nof  goods  that\t are sold by these  assessees  viz.  leather
\nsplits and coloured leather. The splits are the cut  pieces,
\noften  small and irregular, obtained in the process of\tcut-
\nting  raw  of tanned hides and skins either with a  view  to
\nreduce their thickness or with a view to give them a regular
\nshape.\tColoured leather is obtained when the  tanned  hides
\nand skins are dyed with various colours. The assessee, inter
\nalia, deal in these two items, their manner of such  dealing
\nvarying\t from case to case. Some of them obtain the  leather
\nsplits in the process of cutting and sell them while
\n449<\/span>
\nsome  purchase the cuttings and sell them as such. So  also,
\nthe coloured leather is obtained by some of the assessees in
\nthe  process  of finishing and they sell them  while  others
\npurchase  the  coloured leather and sell them as  such.\t The
\nassessees’ claim is that these two items fall in the list of
\n“goods\tof special importance in inter-State trade and\tcom-
\nmerce”\tset out in S. 14 of the Central Sales Tax Act,\t1956
\n(the  ‘CST Act’) and that, therefore, the assessee is  enti-
\ntled,  in respect of their sales, to the concessions  avail-
\nable under s. 15 of the CST Act viz. the benefits of  single
\npoint taxation and of a smaller rate of tax. The sole  ques-
\ntion in these appeals is whether the High Court was right in
\nupholding  this\t claim. The principal judgment of  the\tHigh
\nCourt  on  this point has been reported as Mahi\t Traders  v.
\nState of Tamil Nadu, [1980] 45 S.T.C. 327.\n<\/p>\n
The relevant entry in s. 14 of the CST Act reads:
\n“14(1)(iii)  hides  and skins, whether in a raw\t or  dressed
\nstate. ”\n<\/p>\n
The short case of the department is: (a) that leather splits
\nor cuttings are “scrap” and do not qualify any longer to  be
\ndescribed as hides and skins; and (b) that coloured  leather
\nis a totally new and sophisticated product known as  leather
\nand  can no longer be described merely as hides\t and  skins.
\nThe  department’s case is best explained in a  passage\tfrom
\nthe order of the Board of Revenue which accepted the depart-
\nment’s contention. It observed:\n<\/p>\n
\t      “The  contentions\t have  been  examined\twith
\n\t      reference to the connected records. The splits
\n\t      are  only\t pieces of leather obtained  in\t the
\n\t      process  of getting leather of uniform  thick-
\n\t      ness from dressed skins. Such splits cannot be
\n\t      treated  as dressed hides and declared  goods.
\n\t      The  expression “raw or dressed skin” in\tsec-
\n\t      tion  14\tof the Central Sales Tax Act  has  a
\n\t      distinct connotation and it cannot be extended
\n\t      to  leather bits obtained in a process.  These
\n\t      splits are of much lesser value and cannot  be
\n\t      equated  to dressed skins. In 27\tS.T.C.\tpage
\n\t      385  the\tOrissa High Court has held  that  if
\n\t      steel  plates are cut to sizes, they cease  to
\n\t      be  the original product. What should be\tcon-
\n\t      sidered  is whether those leather\t splits\t are
\n\t      commercially  understood as dressed hides\t and
\n\t      skins.  If  they are understood only  as\tjust
\n\t      skins  as\t claimed, there is no need  to\tcall
\n\t      them  as\tsplits in commercial  parlance.\t The
\n\t      Courts have repeatedly ruled that the  entries
\n\t      in the Act
\n\t      450<\/span>
\n\t      should  be treated only as understood  by\t the
\n\t      Trade.  These splits were produced before\t the
\n\t      Board at the time of hearing. They were  found
\n\t      to  be thin pieces which can be utilised\tonly
\n\t      for  miscellaneous  purposes.  The  contention
\n\t      that  these  leather  splits  continue  to  be
\n\t      dressed skins and are declared goods of inter-
\n\t      state importance, is untenable. The  assessing
\n\t      officer was therefore right in treating  these
\n\t      splits as scraps and taxing them at the multi-
\n\t      point  rate, and in the absence of ‘C’  forms,
\n\t      at 10%.\n<\/p><\/blockquote>\n
\t\t\tAs regards the coloured skins,\tonce
\n\t      the  dressed  skins bought are split  and\t the
\n\t      upper  layer  of uniform size is\tcoloured  or
\n\t      dyed,  such  coloured skins  become  different
\n\t      products.\t They are finished leather  sold  as
\n\t      coloured skins and not as dressed skins.\tThey
\n\t      are  commercially different, and\tare  treated
\n\t      and  dealt with in trade circles as  different
\n\t      products.\t The process of dyeing or  colouring
\n\t      changes  the commercial nature of the  dressed
\n\t      skins. There are different patterns of  dyeing
\n\t      and colouring. The complete piece may be\tdyed
\n\t      or coloured uniformly with a single colour  or
\n\t      with a pattern of colours, depending upon\t the
\n\t      requirements  of the prospective consumers  in
\n\t      the market. As the dressed skins are subjected
\n\t      to process, first by splitting and secondly by
\n\t      colouring\t they  become  different   products.
\n\t      Pieces  of  coloured  and\t dyed  leather\twere
\n\t      produced\tbefore\tthe  Board at  the  time  of
\n\t      hearing.\tSome  pieces were  coloured  With  a
\n\t      single  colour  on one side and  dyed  on\t the
\n\t      reverse.\tThey  can be used  straightaway\t for
\n\t      manufacturing leather goods. They were also in
\n\t      patterns.\t The  contention that no  change  is
\n\t      involved\thas  therefore no  force.  Both\t the
\n\t      Appellate\t  Assistant  Commissioner  and\t the
\n\t      Assessing\t Officer were not therefore  correct
\n\t      in allowing exemption.”\n<\/p><\/blockquote>\n
     On\t the other hand, on behalf of the assessees,  refer-\n<\/p><\/blockquote>\n
ence  is made to certain circulars of the authorities  which
\ncontain\t a contemporaneous exposition of the meaning of\t the
\nentry in question, reliance is placed on the decision of the
\nSales  Tax  Appellate  Tribunal to the contrary\t and  it  is
\nemphasised  that, to say that the one item is called  scraps
\nand  the other is called leather is not sufficient  to\ttake
\nthem  out of the description “hides and skins, in a  raw  or
\ndressed\t state”. It is submitted that cuttings of hides\t and
\nskins do not cease to be hides and skins merely because they
\nare  small pieces and can be loosely described as  “scraps”.
\nSo far as coloured leather is concerned, according
\n451<\/span>
\nto  the assessee, the question is not whether  the  coloured
\nskin is described as leather or whether it is a new  product
\ndifferent from hides and skins, as understood generally, but
\nwhat  exactly is the scope of the expression used  in  entry\n<\/p>\n
(iii)  of s. 14(1). The submission is that hides  and  skins
\nare  generally described as leather even as soon as  tanning
\nis  done but the entry in the statute goes much beyond\tthis
\nstage.\tIt takes in all categories of hides and skins  right
\nfrom  their raw condition, through various stages  of  their
\ntanning and other processing, right upto the stage when they
\nreceive the final finishing touches.\n<\/p>\n
    We\thave heard learned counsel on both sides  at  length
\nand  come to the conclusion that the assessees are  entitled
\nto the benefit of Ss. 14 and 15 of the CST Act in respect of
\nthe  two  items\t in question. As far as the  first  item  is
\nconcerned,  it\tis  common ground that\tleather\t splits\t are
\nnothing\t but cut pieces of hides and skins. We fail  to\t see
\nhow  they cease to be hides and skins. It is no\t doubt\ttrue
\nthat they are cheaper and have a separate name but the\tname
\nonly  indicates that they are cut pieces. It is not  because
\nthey  have  ceased to be hides and skins  and  constitute  a
\ndifferent   commercial\tcommodity  that\t they\tare   called
\n‘scraps’. Some of the dealers purchase and sell such  splits
\nand  such turnover is considerable. There is no material  to
\nsuggest that they are useless or worthless articles. A loose
\ndescription  of them as ‘scrap’ cannot deprive them  of\t the
\nbenefit of s. 14 of the Act.\n<\/p>\n
    Turning  to\t coloured leather, we may,  at\tthe  outset,
\nrefer  to a very important circumstances referred to by\t the
\nrespondents. When the CST Act came into force on 1.4.1957, a
\nquestion was raised regarding the meaning of the  expression
\n‘hides and skins in dressed state’ used in s. 14. The matter
\nwas referred to the leather development wing of the Ministry
\nof Commerce and Industry which gave the following opinion:\n<\/p>\n
\t      “Hides  and  Skins are  obtained\tfrom  either
\n\t      slaughtered or dead animals. The raw hides and
\n\t      skins  thus  obtained are known to be  in\t the
\n\t      Green State. These are easily putrescible;  if
\n\t      proper  precautions are not taken\t they  would
\n\t      easily rot and decay. Since tanneries are\t not
\n\t      always  located  very near the source  of\t raw
\n\t      hides  and skins, the question  of  preserving
\n\t      them for a temporary period till they reach  a
\n\t      tanning  centre assumes importance. Raw  hides
\n\t      and  skins are ‘cured’ by either wet  salting,
\n\t      dry  salting or drying. In the  ‘cured  state’
\n\t      the  raw\tmaterials  can be  preserved  for  a
\n\t      temporary period. In the third state of tempo-
\n\t      rary preserva-\n<\/p><\/blockquote>\n
\t      452<\/span><\/p>\n
\t      tion, the hides and skins are ‘picked’. During
\n\t      the next stage they are tanned in which  state
\n\t      they  can\t be preserved  almost  indefinitely.
\n\t      These  tanned  hides and skins  are  processed
\n\t      further to yield Dressed Hides and Skins which
\n\t      are  ready  for  use.  ‘Dressed’\tor  finished
\n\t      material could also be preserved almost indef-
\n\t      initely.\n<\/p><\/blockquote>\n
\t\t       From the above, it will be seen\tthat
\n\t      the expression ‘Hides and Skins in the raw  or
\n\t      dressed  State’ refers at one end to  the\t raw
\n\t      material obtained from the slaughtered or dead
\n\t      animals and at the other end to the tanned and
\n\t      finished material; the expression,  therefore,
\n\t      seems to include the other intermediate stages
\n\t      indicated\t in the previous paragraphs.  Dress-
\n\t      ing, according to the authoritative  interpre-
\n\t      tations,\twould mean the conversion of  tanned
\n\t      hides and skins by further suitable processing
\n\t      into  leathers  of different types  which\t are
\n\t      ready  for  use” (vide SBT\/  .  18(495\/14)  of
\n\t      November 11, 1957).<\/p><\/blockquote>\n
    It\twould seem though this is not quite clear  from\t the
\nrecord, that this opinion held the field for quite some time
\nuntil the assessments presently in question were made.\tEven
\nhere,  as  pointed out by the High Court,  the\tdepartmental
\nview  was  not quite consistent. The Deputy  Commercial\t Tax
\nOfficer,  in some of the cases, was willing to concede\tthat
\ncoloured  leather, notwithstanding the colouring,  continued
\nto  be\tdressed\t hides and skins but  thought  that  leather
\nsplits\tshould be brought to multipoint tax.  The  Assistant
\nCommissioner,  on  the contrary, took the view\tthat  splits
\nwould  continue to be hides and skins. It was the  Board  of
\nRevenue that decided that both items would fall outside\t the
\npurview of item (iii) in section 14(1).\n<\/p>\n
    It\thas  been pointed out by this court in\tDesh  Bandhu
\nGupta  and Ors. v. Delhi Stock Exchange,<\/a> [1979] 4  SCC\t565,
\nand Varghese v. ITO, [1981] 131 ITR 597 that a contemporane-
\nous  exposition by the administrative authorities is a\tvery
\nuseful\tand  relevant  guide to the  interpretation  of\t the
\nexpressions’  used in a statute. Considering that the  above
\nclarification  was sought for at the earliest point of\ttime
\nwhen a doubt arose as to the scope of the expression used by
\nthe  statute and given after considering the  technicalities
\nof  the\t processes employed in the manufacture\tof  finished
\nleather by the department fully conversant with this  branch
\nof  trade and in the context of the provisions of this\tvery
\nstatute,  the terms of the statute can well be construed  by
\nreference to such exposition, in the absence of anything  in
\nthe statute
\n453<\/span>
\nto  indicate  the  contrary.  Indeed,  “such  interpretation
\nshould\t be  shown  to\tbe  clearly  wrong  before   it\t  is
\noverturned.”\n<\/p>\n
    Can\t it  then be said that the view expressed  above  is
\nclearly wrong? We think not; on the contrary, it is seen  to
\nbe quite correct. The statutory expression refers to  “hides
\nand  skins  in a dressed state”. The guidelines\t issued\t for
\nidentification\tof  ‘finished’ leather for  exports  by\t the
\nIndian\tStandards Institution (ISI) refer to as many  as  19
\noperations  or\tprocesses undergone  during  manufacture  of
\n‘finished  leather’  but ‘dressing’ is not one\tof  them.  A
\nglossary  of  terms  relating to hides,\t skins\tand  leather
\npublished  by  the  I.S.I. in 1960  contains  the  following
\ndefinitions:\n<\/p>\n
\t      CRUSTS:  (Crust  Leather)–Tanned\t hides\t and
\n\t      skins without any finish.\n<\/p><\/blockquote>\n
\t      CURRYING:\t A series of dressing and  finishing
\n\t      processes applied to leather after tanning  in
\n\t      the  course  of which appropriate\t amounts  of
\n\t      oils  and\t greases  are  incorporated  in\t the
\n\t      leather to give it increased tensile strength,
\n\t      flexibility and resisting properties.
\n\t      DRESSED RIDES: Tanned hides, curried or other-
\n\t      wise  finished, for various purposes, such  as
\n\t      belting,\tharness and saddlery,  travel  goods
\n\t      and for upholstery.\n<\/p><\/blockquote>\n
\t      DRESSING LEATHER: Vegetable tanned hides which
\n\t      may  be dressed to suit the purpose for  which
\n\t      they  are\t to be used, such  as  for  harness,
\n\t      saddlery and other mechanical purposes.
\n\t      LEATHER: The skin or hide of animals  prepared
\n\t      by  tanning, which still retains its  original
\n\t      fibrous  structure  more or less\tintact,\t but
\n\t      from  which hair or wool may or may  not\thave
\n\t      been removed and which has been treated so  as
\n\t      to be imputrescible even after treatment\twith
\n\t      water.<\/p><\/blockquote>\n
    The\t earlier  glossary of such terms  published  by\t the
\nBritish\t Standards  Institution\t defines  ‘dressing’  as   a
\n“general  term for the series of processes employed to\tcon-
\nvert  certain  rough  tanned hides and\tskins  and\/or  crust
\nleather\t into  leather ready for use.”\tAlso,  “Leather”  is
\ndefined\t as  “a general term for hide or  skin\twhich  still
\nretains its original fibrous structure more or less  intact,
\nand which has
\n454<\/span>
\nbeen treated so as to be imputrescible even after  treatment
\nwith  water.”  The  hair or wool may or may  not  have\tbeen
\nremoved.  Certain skins, similarly treated or  dressed,\t and
\nwithout\t the hair removed, are termed ‘fur’. The  Dictionary
\nof Leather Terminology published by the Tanners’ Council  of
\nAmerica,  describes  leather as “the hide and  skin  of\t any
\nanimal\tor any portion of such skin, when tanned,  tawed  or
\notherwise dressed for use.”\n<\/p>\n
    The above definitions show that hides and skins  acquire
\nthe name of ‘leather’, even if the hair or wool has not been
\nremoved\t therefrom, as soon as they receive  some  treatment
\nwhich  prevents them from putrefaction after treatment\twith
\nwater. Dressing is a stage much later than tanning.  Indeed,
\nfrom  the definitions quoted above, it will be seen that  it
\nis  practically the same as giving finishing touches to\t the
\nleather\t and making it suitable for the manufacture of\tpar-
\nticular types of goods.\n<\/p>\n
    Sri Sen invited our attention, apart from the  contempo-
\nraneous exposition by the Department, to the findings of the
\nTribunal  in  this regard in an earlier case which  had\t not
\nbeen  appealed against by the Department. The  Tribunal\t had
\nsaid:\n<\/p>\n
\t      “We  have carefully considered the records  as
\n\t      well as the arguments. We have seen the speci-
\n\t      mens  of the articles sold. Bits of  the\tsame
\n\t      are also on record. We have carefully  scruti-
\n\t      nised the same. We are unable to say that what
\n\t      the  appellants had sold is not leather or  in
\n\t      other words dressed hides and skins. The\tfact
\n\t      that the appellant has done some more  finish-
\n\t      ing would not take away the resultant  product
\n\t      from  the classification. We do find that\t the
\n\t      clarification issued by the Board of  Revenue,
\n\t      Madras  and  the Govt. of India  supports\t the
\n\t      appellants case. The expert opinion which only
\n\t      says that the resultant product has  undergone
\n\t      some chemical changes observed as under:
\n\t\t       It  is, surely a\t different  product,
\n\t      because it is a finished leather. It  however,
\n\t      retains the leathery properties of the dressed
\n\t      leather.\n<\/p><\/blockquote>\n
\t      Hence  the expert opinion also fully  supports
\n\t      the  appellants case inasmuch as\tit  concedes
\n\t      that the resultant product is ‘finished leath-
\n\t      er’.  It is because the issue  in\t appellant’s
\n\t      case is not whether the appellant was  selling
\n\t      a different product
\n\t      455<\/span>
\n\t      from  the\t one it purchased, but\twhether\t the
\n\t      appellant was selling tanned leather. In\tthis
\n\t      case, we do not find any factual basis even to
\n\t      cast any doubt upon the appellant’s claim.  It
\n\t      is a pity that the assessing authority  should
\n\t      have followed the audit objections without the
\n\t      application of his own mind. Leather from\t the
\n\t      stage  of\t raw skins to the stage\t of  dressed
\n\t      hides and skins may undergo various stages  of
\n\t      changes.\tUnder  the  classification  for\t the
\n\t      purposes\tof section 14 of the  Central  Sales
\n\t      Tax  Act, the various stages  are\t irrelevant.
\n\t      For  the purposes of Tamil Nadu General  Sales
\n\t      Tax Act, 1959, only two stages that are  rele-
\n\t      vant  are the skins at the raw stage  and\t the
\n\t      skins  in the form of dressed hides and  skins
\n\t      (or  tanned  hides and skins).  The  appellant
\n\t      purchases semifinished leather and  undertakes
\n\t      further  process of finishing with a  view  to
\n\t      colour the hides and skins for certain uses of
\n\t      skins.  He  says that he\tpurchased  the\tsame
\n\t      tanned  hides  and skins and sold\t the  tanned
\n\t      hides and skins. According to him the products
\n\t      purchased\t and  sold are\tnot  different\teven
\n\t      under the classification by way of the dichot-
\n\t      omy  between raw and dressed hides  and  skins
\n\t      under  the Tamil Nadu General Sales  Tax\tAct.
\n\t      Under the Central Sales Tax Act, the appellant
\n\t      is in a much better position, because all\t the
\n\t      hides  and skins are brought together  in\t one
\n\t      entry.  Whether  raw or dressed,\tthe  product
\n\t      falls under the same entry.”\n<\/p><\/blockquote>\n
We  are of opinion that this represents the correct view  of
\nthe scope of the entry in question.\n<\/p>\n
    The same conclusion is further borne but by the  litera-
\nture  referred to before us by Sri Ramachandran. Vol.  7  of
\nthe  Encyclopedia  Brittanica, under the word  “dress”,\t ex-
\nplains\tthat the verb has various applications which can  be
\ndeduced from its original meaning and that “it is thus\tused
\nnot  only of the putting on of the clothing but of the\tpre-
\nparing\tand finishing of leather  …….  “Vol.  17,  under
\nthe head “leather” details the various processes applied  in
\nthe treatment of hides and skins at all stages, pre-tanning,
\ntanning\t and post-tanning. Dyeing or colouring is a  process
\nwhich follows tanning but precedes “finishing” (i.e.  dress-
\ning) in order to make it suitable for the purpose for  which
\nit is required in commercial usage. Part V of the “Wealth of
\nIndia”,\t a  publication\t of the Council\t of  Scientific\t and
\nIndustrial  Research  (1966),  dealing\twith  leather  under
\n“Industrial  Products”\texplains that “hides and  skins\t are
\nliable to putrefaction and loss unless
\n456<\/span>
\nsuitably treated and converted into leather.”  Structurally,
\nhides  and  skins have a thick middle layer  called  corium,
\nwhich  is  converted to leather by tanning.  The  operations
\ninvolved  in  leather manufacture however  fall\t into  three
\ngroups.\t Pre-tanning  operations  include  soaking,  liming,
\ndeliming,  bating and pickling, and post tanning  operations
\nare splitting and shaving, neutralising, bleaching,  dyeing,
\nfat-liquoring  and stuffing, setting out,  samming,  drying,
\nstaking and finishing. These operations bring about chemical
\nchanges in the leather substance and influence the  physical
\ncharacteristics\t of the leather, and different varieties  of
\ncommercial  leather are obtained by suitably  adjusting\t the
\nmanufacturing  operations. These processes need not be\tgone
\ninto  in  detail but the passages relied upon  clearly\tshow
\nthat  hides and skins are termed ‘leather’ even as  soon  as
\nthe  process  of  tanning is over and the  danger  of  their
\nputrefaction  is  put an end to. The entry in the  CST\tAct,
\nhowever,  includes  within its scope hides and\tskins  until
\nthey  are ‘dressed’. This, as we have seen,  represents\t the
\nstage when they undergo the process of finishing and  assume
\na form in which they can be readily utilised for manufacture
\nof  various commercial articles. In this view, it is  hardly
\nmaterial  that coloured leather may be a form of leather  or
\nmay even be said to represent a different commercial commod-
\nity. The statutory entry is comprehensive enough to  include
\nthe products emerging from hides and skins until the process
\nof dressing or finishing is done.\n<\/p>\n
    We\tare, therefore, of the view that the High Court\t was
\nright  in holding that ‘splits’ and ‘coloured leather’\tcon-
\ntinue  to be hides and skins eligible for special  treatment
\nunder the CST Act. All the appeals, therefore, fail and\t are
\ndismissed. We however make no order as to costs.\n<\/p>\n
G.N.\t\t\t\t\t       Appeals\tdis-\nmissed.\n457<\/span>\n\n\n\n<\/pre>\n","protected":false},"excerpt":{"rendered":"
Supreme Court of India State Of Tamil Nadu vs Mahi Traders & Ors. Etc. Etc on 3 February, 1989 Equivalent citations: 1989 AIR 1167, 1989 SCR (1) 445 Author: S Rangnathan Bench: Rangnathan, S. PETITIONER: STATE OF TAMIL NADU Vs. RESPONDENT: MAHI TRADERS & ORS. ETC. ETC. DATE OF JUDGMENT03\/02\/1989 BENCH: RANGNATHAN, S. BENCH: RANGNATHAN, […]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"_lmt_disableupdate":"","_lmt_disable":"","_jetpack_memberships_contains_paid_content":false,"footnotes":""},"categories":[30],"tags":[],"class_list":["post-46455","post","type-post","status-publish","format-standard","hentry","category-supreme-court-of-india"],"yoast_head":"\nState Of Tamil Nadu vs Mahi Traders & Ors. Etc. 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