{"id":55445,"date":"2001-12-11T00:00:00","date_gmt":"2001-12-10T18:30:00","guid":{"rendered":"https:\/\/www.legalindia.com\/judgments\/the-west-coast-paper-mills-ltd-vs-the-commercial-tax-officer-on-11-december-2001"},"modified":"2015-10-12T10:00:06","modified_gmt":"2015-10-12T04:30:06","slug":"the-west-coast-paper-mills-ltd-vs-the-commercial-tax-officer-on-11-december-2001","status":"publish","type":"post","link":"https:\/\/www.legalindia.com\/judgments\/the-west-coast-paper-mills-ltd-vs-the-commercial-tax-officer-on-11-december-2001","title":{"rendered":"The West Coast Paper Mills Ltd vs The Commercial Tax Officer on 11 December, 2001"},"content":{"rendered":"
Madras High Court<\/div>\n
The West Coast Paper Mills Ltd vs The Commercial Tax Officer on 11 December, 2001<\/div>\n
       \n\n  \n\n  \n\n \n \n  In the High Court of Judicature at Madras\n\n Dated: 11.12.2001\n\n Coram \n\nThe Honourable Mr.Justice R.Jayasimha Babu   \n\nand \n\nThe Honourable Mr.Justice A.K.Rajan \n\n Writ Petitions No.9767 to 9768 of 2000 and WPNOs.17649 to 17653 of 2000  \n\n The West Coast Paper Mills Ltd.,\n39 A, Brahmin Street,\nCuddalore District.                     Petitioner in all\n                                        the Writ Petitions\n\nvs.\n\n 1. The Commercial Tax Officer,\n   Cuddalore.                           Respondent 1 in \n                                        all the petitions\n\n2. The Tamil Nadu Sales Tax \n    Appellate Tribunal, rep.\n    by its Secretary,\n   City Civil Court Buildings,\n   Chenani 600 104.                     Respondent 2 in \n                                        Wps.No.9767 and  \n                                         9768\/2000 \n\n3. The Tamil Nadu Taxation\n        Special Tribunal,\n   Singarvelar Maaligai,\n   Chennai 1.                           Respondent 2 in \n                                        WPs 17649 to 17653 of 2000 and  \n                                        Respondent 3 in \n                                        Wps.9767&9768\/2000   \n\n\n\n        Writ Petitions No.9767 and 9768 of 2000 are filed  under  Article\n226  of  the  Constitution  of  India  praying  for  the issue of writ of\ncertiorari calling for the records of the  Tamil  Nadu  Taxation  Special\nTribunal  in  it's  order  in  T.C.(R)  No.1468  and  1467  of 1997 dated        \n16.02.2000 confirming the  assessment  of  the  Commercial  Tax  Officer,       \nCuddalore  in TNGST No.582029\/86-87 and 186709\/84-85 dated 19.11.1987 and    \n29.12.1 987 respectively along with the orders of the  Tamil  Nadu  Sales\nTax Appellate  Tribunal  in T.A.  No.917 and 916 of 1987 dated 24.04.1990\nand to quash the orders of the Tamil Nadu Taxation Special Tribunal in so\nfar as it relates to the tax imposed under Section 7-A of the Tamil  Nadu\nGeneral Sales Tax Act, 1959. \n\n        Writ  petitions No.17649 to 17653 of 2000 filed under Article 226\nof the Constitution of India for the issue of writ of certiorari  calling\nfor  the  records on the file of the Tamil Nadu Taxation Special Tribunal\nin O.Ps.  No.1246, 1250, 1247, 1249 and 1248  of  2000  respectively  and\nquash the  order  made  in  that  O.Ps.  Dated 28.09.2000, confirming the\nproceedings of the  Commercial  Tax  Officer,  Cuddalore  in  TNGST  No.5\n82029\/89-89;  93-94,  90-91,  92-93  and 91-92 respectively dated 28.07.2\n000.\n\n\n\n!       For Petitioner  :  Mr.C.Natarajan,\n                        Senior Counsel, for\n                        Mr.N.Inbarajan\n\n^       For Respondents :  Mr.T.Ayyasamy,  \n                        Special Goverment Pleader (T)\n\n\n:                                 ORDER  \n<\/pre>\n
(Order of the Court was made by
\nR.Jayasimha Babu, J.) <\/p>\n
        Petitioner is a manufacturer of paper.  It has its paper mill  in
\nthe State  of Karnataka.  It had, during the years 1984 to 1992 purchased
\n`Casuarina Wood’ in dimension of 0.6 metres length and 5 cms.   width  at
\nthe  thin  end,  from  farmers in Tamil Nadu in circumstances in which no
\nsales tax was payable by reason of the farmers not being dealers and  not
\nbeing  liable  to  pay  tax,  even  though  firewood is taxable under the
\nresiduary entry in the first schedule to the Tamil Nadu General Sales Tax
\nAct, hereinafter referred to as the Act.  The rate  of  tax  during  that
\nperiod ranged between 3% to 5%.\n<\/p>\n
        2.   The  petitioner  was  assessed  to  purchase tax by invoking
\nSection 7A of the  Act.    The  dealers’  objection  that  casuarina  was
\nfirewood  in  respect  of which the Government had by its notification of
\n4th March 1974, issued under Section 17(1) of the Act granted  exemption,
\nand  therefore  no  purchase  tax  could  be levied, was overruled by the
\nassessing officer, whose order was upheld in appeals,  preferred  by  the
\ndealer to the appellate Tribunal and to the Special Taxation Tribunal.\n<\/p>\n
        3.  Learned counsel for the petitioner submitted that `Casuarina’
\nis  indeed  firewood  and  in  support  of that submission he invited our
\nattention to several publications dealing with `Casuarina’.  In the  book
\n“Casuarinas” by Dr.N.S.Subbarao and C.Rodriguez Barrueco published in the
\nyear  1995,  the  authors  being  acknowledged  experts in their field of
\nstudy, in the Chapter “Uses and Economics” it is stated that the bulk  of
\nCasuarina wood is used as fuel in India and China.  In the preface by the
\nauthors,  it  is  also noted that there have been many uses for Casuarina
\nwood apart from its utility as an ideal source of fuel;  that  Casuarinas
\nare  excellent  for  landscaping, sandbinding, windbreaks in agroforestry
\nand above all rural house construction requiring inexpensive  wood;  that
\nCasuarinas  are  regarded  as  multi  purpose  trees requiring no special
\nchemical inputs or agronomic practices to raise large  plantations  on  a
\nslender  budget, and Casuarinas are indeed a boon to the poor who require
\nfuel as well as shelter at minimum cost.  The wood itself is described as
\npale, brown, strong, heavy and straight grained.  When  young  it  weighs
\n800  kg\/m and when old it weighs 96 8 kg\/m at 12 percent moisture content
\nof wood.  The calorific value of 1 kg wood is 4127 kcal.\n<\/p>\n
        4.   Counsel  also  placed  before  us   “A   Handbook   on   the
\nIdentification  and Description of Trees, Shrubs and Some Important Herbs
\nof the Forests of the Southern States” published by the  Southern  Forest
\nRangers  College, Coimbatore, in which `Casuarina’ is described as a fast
\ngrowing, conifer-like, evergreen tree, stem erect, branching  monopodial,
\nends   of  branchlets  thickly  set  with  numerous  long  slender  green
\nbranchlets which are mostly deciduous branchlets jointed; internodes  0.5
\n 0.64  cm, 6  8 ribbed.  As regards it’s uses it is stated therein that
\n“Wood is useful for scaffolding poles, rafters, etc.   chiefly  used  for
\nfuel;  tree  is  particularly  valuable for afforesting sandy beaches and
\nshifting sand dunes along sea coast; bark sometimes used in tanning and a
\nbrown dye is extracted from it.”\n<\/p>\n
        5.  In  the  book,  “Casuarinas    Trees  of  Multiple  Utility”
\npublished by the Indian Council of Forestry Research and Education in the
\nyear  1 992, it is stated by the Director General of that Institute that,
\n” Casuarina equisetifolia” was introduced into India in the 19th  century
\nto fuel steam locomotives.  Since then it had slowly gained importance as
\na  multipurpose  tree  to  meet  the requirements of rural folk for fuel,
\nfodder, poles for farm constructions,  shelter  belts  in  area  of  high
\nvelocity winds, and even arresting sand dunes in coastal areas.  Recently
\nindustries have also shown a keen interest in this species as a source of
\npulp  for  manufacture of paper and rayons and that the bark and wood can
\nbe used for a number of purpose.” In the Chapter relating to  Utilization
\nof  the tree, under the head “Industrial Uses” it is stated that in India
\nthis wood has been found to make a good paper pulp through use of neutral
\nsulphate and semi chemical process; that it is used for  making  wrapping
\npapers and printing papers; that one of the paper mills in Andhra Pradesh
\nin  the year 1988-89 consumed as much as 68,329 metric tons of Casuarina,
\nto make pulp wood.  Under the head  “Domestic  and  Other  Uses”,  it  is
\nstated that Casuarinas the world over became important with the advent of
\nthe  energy crisis, and it is estimated that 85% of the wood harvested in
\ndeveloping countries  is  used  for  fuel  of  which  Casuarina  forms  a
\nsignificant  component  and  that the most universal use of Casuarinas is
\nfor fuel, as the wood is dense and burns slowly with great  heat  and  no
\nsmoke and further that it can even be burnt when green.\n<\/p>\n
        6.   Reference  was  also  made  to  the  publication, “Casuarina
\nProduction and Marketing in Tamil Nadu” published by the  Forest  College
\nand  Research Institute, Coimbatore, in which it is stated that the trees
\nare cut into different grades like building poles, firewood and that  the
\ntop  portion  of  the  trees are called as “Millers” and that approximate
\nspecifications adopted for Casuarina used as centering poles is 10    12
\nft height with 3″ girth at the top and 5 to 6″ girth at the bottom; 15 to
\n25 ft.   height for scaffolding poles; 3 ft.  length for firewood and 3.5
\nft.  length for pulpwood billets.  It is also  mentioned  in  that  study
\nthat  about  10%  of the Casuarinas grown in Villupuram District of Tamil
\nNadu is bought by the petitioner herein for use in it’s pulp plant.\n<\/p>\n
        7.  The material purchased by the petitioner clearly  shows  that
\nCasuarina  is  indeed  a wood which is used as firewood, although it is a
\nmulti purpose tree and is capable of being put to use for  several  other
\npurposes  and  particularly  as  centering poles, for scaffolding and for
\nsupporting temporary structures.  One of the ways in which  it  has  been
\nput to  use is for making pulp.  The question for consideration therefore
\nis as to whether by reason of the Casuarina being used for  making  pulp,
\nit ceases to be firewood.\n<\/p>\n
        8.   The  Supreme  Court  in the case of Mukesh Kumar Agarwal vs.
\nState of Madhya Pradesh and others, 68 STC  324,  while  considering  the
\nquestion  as  to whether the wood-heaps after the extraction of poles and
\nballies of eucalyptus trees was merely firewood held that,
\n“In a taxing statute, words which are not technical expressions or  words
\nof  art,  but  are words of every day use, must be understood and given a
\nmeaning, not in their technical or scientific sense, but in  a  sense  as
\nunderstood  in common parlance, i.e., “that sense which people conversant
\nwith  the  subject-matter  with  which  the  statute  is  dealing,  would
\nattribute to it.”\n<\/p>\n
The  eucalyptus  logs  which were subject matter of the sale in that case
\nbefore the apex Court were also  meant  for  use  in  making  pulp  by  a
\nmanufacturer of synthetic fibre.  The High Court in that case had reached
\nthe  conclusion  that  eucalyptus  was not firewood, and therefore it was
\ntimber.  The apex Court observed that all wood is not  timber  as  indeed
\nall  wood is not firewood either, though perhaps it will not be incorrect
\nto say that both the firewood and timber are woods in its generic  sense.
\nOn  the question as to whether the nature of the goods can be ascertained
\nwith reference to its user, the apex Court observed that,
\n“The `user-test’ is logical, but is, again, inconclusive.  The particular
\nuse to which an article can be applied in the hands of a special consumer
\nis not determinative of the nature of the goods.  Even as the description
\nof  the  goods  by  the  forest  authorities  called  them  varyingly  as
\n`eucalyptus fuel   wood’   `eucalyptus   wood-heap’,   etc.      is   not
\ndeterminative, the fact that purchasers were dealers in  timber  is  also
\nnot conclusive.”\n<\/p>\n
The Court went on to hold that even though eucalyptus, by every reckoning
\nis  a  timber  tree, the subsidiary parts of the tree sold in heaps after
\nthe poles are separated, cannot be regarded as  timber  with  the  sense,
\nsize and utility implicit in the idea of timber.  The Court also observed
\nthat  difference of degree can bring about difference of kind but that no
\ntest of general validity applicable to or governing all cases can at  all
\nbe laid down.\n<\/p>\n
        9.  Casuarina  like  eucalyptus is a tree.  The fact that it is a
\ntree and it’s poles are used for scaffolding or  centring  purposes,  and
\nthe  tree  itself  is  grown  in certain areas with a view to improve the
\nenvironment, would not render all parts of the tree into timber.   Timber
\nand firewood  has implicit in them a reference to their use.  Part of the
\nsame tree can be regarded as timber, while some other parts  may  be  fit
\nfor use  only  as firewood.  Even the difference in degree such as length
\nand breadth may bring about differences of kind.    To  conclude  that  a
\nwhole  species  of tree is either timber or firewood, therefore, does not
\nappear to be permissible.  The actual use to which a specific part of the
\ntree is put is however not determinative of the category into which it is
\nto be placed whether as timber or firewood.\n<\/p>\n
        10.  The question would then be as to whether that  part  of  the
\nCasuarina  tree  which is fit for, and is predominantly used as firewood,
\nceases to be firewood for the purposes of the Act when it is actually put
\nto a different use.  As observed  by  the  Supreme  Court  user  test  is
\nlogical but,  is  inconclusive.   The fact that wood burns when it is lit
\nwould not, on that score, make all wood into firewood.  The term firewood
\ncan be used only when the part suitable for use as firewood, is used  for
\nthat purpose, and such user is it’s primary user.  If such wood is put to
\nother uses, such other use would not render firewood into something other
\nthan firewood, unless wood is classified in the statute with reference to
\nit’s actual use, such as wood used for making pulp.\n<\/p>\n
        11.   In  this  case,  the size of the material to be supplied is
\nsuch, that it is suitable for use as firewood.  That Casuarina itself  is
\nexcellent fuel  is  not in doubt and cannot be doubted.  Though Casuarina
\nPoles may not appropriately be described as firewood, Casuarina  branches
\nand  timber  pieces  of the size for which the petitioner had contracted,
\nbeing predominantly fit for  use  as  firewood  has  to  be  regarded  as
\nfirewood in the absence of any specification in the Act with reference to
\nthe actual use to which such wood is put.\n<\/p>\n
        12.   In the case of Deputy Commissioner of Sales Tax (Law) Board
\nof Revenue (Taxes), Ernakulam vs.    C.R.Paul  &  Sons,<\/a>  59  STC  231,  a
\ndecision  rendered  by the Kerala High Court prior to the decision of the
\napex Court in the case of Mukhesh Kumar Agarwal cited supra, it was  held
\nthat  wood  brought and sold for the purposes of making pulp could not be
\nregarded as firewood as the wood supplied was made specially suitable for
\nthe manufacture of pulp, and  both  the  seller  and  the  purchaser  had
\nconsciously  entered into an agreement for the supply of raw material for
\nthe manufacture of pulp.  The  Court  held  that  reality  could  not  be
\nignored  and the concessional rate of tax provided for firewood could not
\nbe extended to such wood which had  been  described  by  the  parties  as
\ntimber pieces  of specific sizes.  That judgment of the Kerala High Court
\nwas followed by another Bench of the same Court in the case of the Deputy
\nCommissioner of Sales Tax (Law) vs.  M\/s.  Mavoor Trade Links, A.Rajan  &
\nCo.  And others,  T.R.Cs.   No.27, 32, 34 to 38, etc.  Of 1985 decided on
\n1st April, 1986.  That later judgment was  taken  up  in  appeal  to  the
\nSupreme Court in Civil Appeals No.4129 to 4138 of 1988 and was decided on
\n21.11.1988.   The  apex Court set aside that judgment in a brief order in
\nwhich it was stated that in view of the decision of  that  Court  in  the
\ncase  of  Mukesh  Kumar  Agarwal,  the  judgment of the High Court is set
\naside.\n<\/p>\n
        13.  The Kerala High Court itself had much earlier, in  the  case
\nof Deputy  Commissioner vs.  Western India Plywoods (P) Ltd., 46 STC 331,
\nheld that the predominant  or  ordinary  use  of  the  article  would  be
\ndecisive for the purpose of determining it’s nature, and the fact that it
\nis  put  to  use for some other purpose also would not have any impact in
\nit’s proper classification.  The Court upheld the claim of a manufacturer
\nof hardboard who had used the wood purchased by it as raw material,  that
\nit  was  entitled  to  concessional  rate  of tax, as the predominant and
\nordinary use of the wood purchased by it was only as firewood.\n<\/p>\n
        14.  Learned counsel for the Revenue invited our attention to the
\ndecision of this Court in the case of A.H.K.  & Company vs.  The State of
\nTamil Nadu,<\/a> 46 STC 117, in which it was held that specification  for  the
\nsupply  of  the  goods involved in that case indicated that neither party
\nintended that the goods should be sold or bought only as firewood.\n<\/p>\n
        15.  The agreement  between  the  parties  in  this  case  merely
\nprovides for  the  sale of Casuarina Wood of diameter of 0.5 cms.  at the
\nthin end  and  length  of  approximately  0.6  metres.    No  over-sized,
\nundersized,  burnt sandpattered, charred, bent or rotten blinks was to be
\naccepted.  It is obvious that the agreement was not for  supply  of  wood
\nwhich was  to  be  used for firewood.  However, that fact alone would not
\ndetermine the nature of the wood that was supplied.  As observed  by  the
\napex Court in the case of Mukesh Kumar Agarwal, the fact that a purchaser
\nis  a  dealer  in  timber  as  also  the  description of the goods by the
\nauthorities in the department would not be determinative of the nature of
\nthe goods.  Having regard to these observations of the  apex  Court,  the
\nfact that the parties did not intend that the wood sold was to be used as
\nfirewood, would not be decisive of it’s nature.\n<\/p>\n
        16.   What  is  taxed  under  the Act are transactions of sale or
\npurchase involving goods.  The purposes  for  which  the  transaction  is
\nentered  into  is  not  material except to the extent taken note of while
\ngranting the concession in the rate of tax.  Goods have to be  identified
\nfor being what they are.  The same goods cannot be described at different
\npoints  differently  and  varying  rates  of  tax levied, unless a proper
\nclassification is made by the Legislature  itself  or  by  the  authority
\nproperly  delegated  with  such  power if such delegation is permissible.
\nWhen the exemption notification merely uses the term firewood without any
\ncondition or qualification, it must necessarily  follow  that  all  goods
\nwhich  answer the description, and fall within the scope of that term are
\nentitled to exemption.  The fact that the goods which  fall  within  that
\nexemption  are  used  for  a  purpose other than that for which the goods
\ngenerally belonging to that class are used, would not  take  those  goods
\nout  of  that  class,  in  the  absence  of  any other requirement in the
\nstatute.\n<\/p>\n
        17.  It is always open to the Revenue to  qualify  the  exemption
\nwith  reference  to  the  user,  as  the  State is not bound to enact law
\nlevying tax on goods without reference to their user, nor  is  there  any
\nprohibition  in the Act against exemption being granted with reference to
\ntheir user.  If the State has not chosen to clarify  it’s  intention  and
\nhas  not  chosen  to specify any condition subject to which the exemption
\ncan be availed, there is no  alternative  but  to  hold  that  all  goods
\nfalling  within  the  description of the goods mentioned in the exemption
\nnotification will  qualify  for  the  exemption.    For  the  purpose  of
\nascertaining  the  nature  of  the  goods,  it’s  predominant use and the
\npopular sense in which the words used in the notification are  understood
\nwould be  material.    The  special  use for which a particular dealer or
\nbuyer uses those goods will not render those goods into  something  other
\nthan  what  they normally are, having regard to their nature and dominant
\nand ordinary user.\n<\/p>\n
        18.  The writ petitions are allowed.\n<\/p>\n
                                        11.12.2001 <\/p>\n
Index :  Yes <\/p>\n
Web site :  Yes\/No <\/p>\n
To<\/p>\n
1.  The Commercial Tax Officer,
\nCuddalore.\n<\/p>\n
2.  Secretary,
\nThe Tamil Nadu Sales Tax
\nAppellate Tribunal,
\nCity Civil Court Buildings,
\nChenani 600 104.\n<\/p>\n
3.  The Tamil Nadu Taxation
\n        Special Tribunal,
\nSingarvelar Maaligai,
\nChennai 1.\n<\/p>\n
gp\/mf<\/p>\n
R.Jayasimha Babu, J.\n<\/p>\n
And <\/p>\n
A.K.Rajan, J.\n<\/p>\n
W.Ps.9767, 9768,
\n17649 to 17653 of 2000 <\/p>\n
11.12.2001 <\/p>\n","protected":false},"excerpt":{"rendered":"
Madras High Court The West Coast Paper Mills Ltd vs The Commercial Tax Officer on 11 December, 2001 In the High Court of Judicature at Madras Dated: 11.12.2001 Coram The Honourable Mr.Justice R.Jayasimha Babu and The Honourable Mr.Justice A.K.Rajan Writ Petitions No.9767 to 9768 of 2000 and WPNOs.17649 to 17653 of 2000 The West Coast […]<\/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":[8,13],"tags":[],"class_list":["post-55445","post","type-post","status-publish","format-standard","hentry","category-high-court","category-madras-high-court"],"yoast_head":"\nThe West Coast Paper Mills Ltd vs The Commercial Tax Officer on 11 December, 2001 - Free Judgements of Supreme Court & High Court | Legal India<\/title>\n<meta name=\"robots\" content=\"index, follow, max-snippet:-1, max-image-preview:large, max-video-preview:-1\" \/>\n<link rel=\"canonical\" href=\"https:\/\/www.legalindia.com\/judgments\/the-west-coast-paper-mills-ltd-vs-the-commercial-tax-officer-on-11-december-2001\" \/>\n<meta property=\"og:locale\" content=\"en_US\" \/>\n<meta property=\"og:type\" content=\"article\" \/>\n<meta property=\"og:title\" content=\"The West Coast Paper Mills Ltd vs The Commercial Tax Officer on 11 December, 2001 - 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