STATE OF TAMIL NADUversusMAHI TRADERS & ORS. ETC. ETC.

                        STATE OF TAMIL NADU                                       A
                                  v.
                    MAHI TRADERS & ORS. ETC. ETC.

                               FEBRUARY 3, 1989

      [SABYASACHI MUKHARJI AND S. RANGANATHAN, JJ.)                               B
l




~·
             Central Sales Tax Act, 1956: Sections 14(J)(iii) & 15-'Leather
      splits', 'Coloured leather'-Whether hides and skins-Eligibility for
      special treatment under the Act.

            Statutory construction-Contemporaneous exposition-Opinion             C
      rendered on meaning of statutory expressions by the Department                  I
      concerned-The terms of the statute can be construed by reference to
      such exposition-In the absence of anything in the statute to indicate the
      contrary.

            Words & phrases: 'Leather sp/its'-Meaning of.                         D

              The respondents are dealers in hides and skins. They deal among
       other things in splits and coloured leather. The splits are the cut pieces,
       small and irregular, obtained in the process of cutting raw or tanned
       hides and skins either with a view to reduce their thickness or to give
       them a regular shape. Coloured leather is obtained when the tanned E
       hides and skins are dyed with various colours. The claim of the respon-
       dents is that these two items fall in the list of "goods of special import-
       ance in inter-State trade and commerce" set out ins. 14 of the Central
     · Sales Tax Act and, therefore, entitled to the concessions available under
       s. 15 of the· Act, namely the benefits of single point taxation and of a
       smaller rate of tax. Such claims were allowed by the. assessing authority F
       in respect of coloured leather and in respect of splits he disallowed the
       claims. The Appellate Assistant Commissioner upheld the order of the
       assessing authority. The Board of Revenue negativated the contention
       that leather splits continued to be dressed skins under declared goods of
       inter-State importance and held that these splits are to be treated as
       'scraps' or to be taxed at the multiple rates. As regards coloured leather G
       the Board held that these are commercially different products and that
       the exemption granted was not correct. The tribunal, in certain cases,
      had held that the assessee was entitled to the concessions claimed in
      respect of both items.

            The respondents moved the High Court by way of Writ Petitions         H

                                        445
    446                   SUPREME COURT REPORTS            11989] 1 S.C.R.

A   and tax revision cases and the High Court upheld the claim of the
    respondents, holding that 'splits' and 'coloured leather' continue to be
    hides and skins eligible for special treatment under the Central Sales
    Tax Act.

          The present appeals by special leave are against those judgments
B   of the High Court.

         The contentions of the appellant-State were that the leather splits
    or cuttings are "scrap" and do not qualify any longer to be described
    merely as hides and skins and that coloured leather is a totally new and
    sophisticated product known as leather and can no longer be described
C   merely as hides and skins and as such cannot qualify for exemption.

        On behalf of the respondents, a reference was made to certain
  circulars of the authorities which contain a contemporaneons exposition
  of the meaning of the entry in question and contended that, to say that
  one item being called scraps and the other as leather would not be
D sufficient to take them out of the description "hides and skins, in a raw
  or dressed state" and cuttings of hides and skins would not cease to be
  hides and skins merely because they are small pieces and can be loosely
  described as "scraps". As for coloured leather, it was contended that
  the exact scope of the expression used in entry (iii) of s. 14(1) which
  referred to 'hides and skins whether in a raw or dressed state' would
E have to be looked into.

          Dismissing the appeals,

          HELD: 1.1. The High Court was right in holding that 'splits' and
    'coloured leather' continue to be bides and skins eligible for special     ),
F   treatment under the Central Sales Tax Act. l456EI                           ~
         1.2 A contemporaneous exposition by the administrative autho-
  rities is a very useful and relevant guide to the interpretation of the
  expressions used in a statute. Considering that the clarification was
  sought for from the Ministry of Commerce at the earliest point of time
G when a doubt arose as to the scope of the expression used by the statute
  and given after considering the technicalities of the processes employ~'(!
  in the manufacture of finished leather by the department fully con-
  versant with this branch of trade and in the context of the provisions of
  this very statute, the terms of the statute can well be construed by
  reference to such exposition, in the absence of anything in the statute to
H indicate the contrary. Indeed, such interpretation should be shown to
                      STATE OF TAMIL NADU v. MAHI TRADERS                      447

 + be clearly wrong before it is overturned. The view of the Ministry was A
       that the expression 'hides and skins in the raw or dressed State' refers
       at one end to the raw material obtained from the slaughtered or dead
       animals and at the other end to the tanned and finished material; the
       expression, therefore, seems to include the other intermediate stages as
       well. 'Dressing' according to the authoritative interpretations, would
 •     mean the conversion of tanned hides and skins by further suitable processing   B
       into leathers of different types which are ready for use. [452F-H; 452B-D I

           Desh Bandhu Gupta and Ors. v. Delhi Stock Exchange, [1979] 4
       SCC 565; Verghesev. l.T.0., [1981] l31ITR597,reliedon.

            Mahi Traders v. State of Tamil Nadu, [1980] 45 STC 327,
       approved.
                                                                                      c

             2. Definitions in this regard show that hides and skins acquire the
       name of 'leather' even if the hair or wool has not been removed there-
       from, as soon as they receive some treatment which prevents them froni
       putrefaction afte.r ti:eatment with water. 'Dressing' is a stage much          D
       later than tanning. Indeed, from the definitions it is clear that it is
       practically the same as giving finishing touches to the leather and
       making it suitable for the manufacture of particular types of goods. The
       findings of the Tribunal in this regard in an earlier case, which had not
       been appealed against by the Department, that under the Central Sales
       Tax Act, the appellant is in a much better position, because all the hides     E
       and skins are brought together in one entry, and whether raw or dres-
       sed, the product falls under the same entry, seems to be the correct view
       of the scope of the entry in question. [454B-D; 455E]

f·           Glossary of terms relating to hides, skins and leather published by
       IS! in !960: Dictionary of Leather Terminology published by the                F
       Tanners' Council of America. Encyclopaedia Britannica Vol. 7 and,
       'Wealth of India'. Part V, a publication of the Council of Scientific and
       Industrial Research, 1966, relied on.

             3. Hides and skins are termed 'leather' even as soon as the process of
       tanning is over and the danger of their putrefaction is put an end to. G
,.).   The entry in the Central Sales Tax Act, however, includes within its
       scope hides and skins until they are 'dressed'. This represents the stage
       when they undergo the process of finishing and assume a form in which
       they can be readily utilised for manufacture of various commercial
       articles. In this view, it is hardly material that coloured leather may be
       a form of leather or may even. be said to represent a different commer- H
    448                   SUPREME COURT REPORTS           [19891 1 S.C.R.

A   cial commodity. The statutory entry is comprehensive enough to
    include the products emerging from hides and skins until the process of
    dressing or finishing is done. [456C-E]

         CIVIL APPELLATE JURISOlCTION: Civil Appeal Nos.
    2665-72 (NT) of 1981 etc. etc.
B
         From the Judgment and Order dated 9.1.1980 of the Madras
    High Court in Tax Case Nos. 894, 895 of 1977, 591, 942, 968, 975 of
    1979 and W.P. Nos. 4951and4952 of 1978.                                    ~j

        S. Padmanabhan, R. Mohan and R.A. Perumal for the
    Appellant.
c
                                                                               )
         T.A. Ramachandran, A.K. Sen, Mrs. J. Ramacha!ltlfi!il, inbarajali,
    P.N. Ramalingam, A.T.M. Sampath and A.V.V. Nair for the
    Respondents.

D         The Judgment of the Court was delivered by

          RANGANATHAN, J. All these civil appeals and special leave
    petitions raise a common question as to the interpretation of an expres-
                                                                               )
    sion used in the Central Sales Tax Act. Some of these matters arise out
    of judgments of the High Court in Tax Revision cases and some out of
E   judgments in writ petitions but the point involved is the same. In view
    of the pendency of the appeals. we grant leave in the special leave
    petitions after condoning the delay in filing some of them and proceed
    to dispose of all the appeals by a common order.

          The respondents are all dealers in hides and skins carrying on
F    1msiness in the State of Tamil Nadu. As is well known, raw hides and

  skins undergo various processes such as cutting, tanning, dyeing, dres-
  sing and finishing before they get converted into finished leather and
  assume a condition fit for the manufacture of various kinds of leather
  articles. The dispute in these appeals is in regard to two items of goods
  that are sold by these assessees viz. leather splits and coloured leather.
G The splits are the cut pieces, often small and irregular, obtained in the
  process of cutting raw of tanned hides and skins either with a view to
  reduce their thickness or with a view to give them a regular shape.
  Coloured leather is obtained when the tanned hides and skins are dyed
  with various colours. The assessee, inter alia, deal in these two items,
  their manner of such dealing varying from case to case. Some of them
H obtain the leather splits in the process of cutting and sell them while
    STATE OF TAMIL NADU v. MAHI TRADERS IRANGANATHAN, J.]                  449

+ some purchase the cuttings and sell them as such. So also, the coloured A
    leather is obtained by some of the assessees in the process of finishing
    and they sell them while others purchase the coloured leather and sell
    them as such. The assessees' claim is that these two items fall in the
    list of "goods of special importance in inter-State trade and commerce"
    set out in S. 14 of the Central Sales Tax Act, 1956 (the 'CST Act') and
•   that, therefore, the assessee is entiled, in respect of their sales, to the   B
    concessions available under s. 15 of the CST Act viz. the benefits of
    single point taxation and of a smaller rate of tax. The sole question in
    these appeals is whether the High Court was right in upho~ding this
    claim. The principal judgment of the High Court on this point has been
    reported as Mahi Traders v. State of Tamil Nadu, [1980) 45 S.T.C. 327.
                                                                                  c
          The relevant entry ins. 14 of the CST Act reads:

                "14(1)(iii) hides and skins, whether in a raw or dressed
                state."
                                                                                  D
    The short case of the department is: (a) that leather splits or cuttings
    are "scrap" and do not qualify any longer to be described as hides and
    skins; and (b) that coloured leather is a totally new and sophisticated
    product known as leather and can no longer be described merely as
    hides and skins. The department's case is best explained in a passage
    from the order of the Board of Revenue which accepted the depart-             E
    ment's contention. It observed:

                "The contentions have been examined with reference to
                the connected records. The splits are only pieces of leather
                obtained in the process of getting leather of uniform thick-
                ness from dressed skins. Such splits cannot be treated as         F
                dressed hides and declared goods. The expression "raw or
                dressed skin" in section 14 of the Central Sales Tax Act has
                a distinct connotation and it cannot be extended to leather
                bits obtained in a process. These splits are of much lesser
                value and cannot be equated to dressed skins. In 27 S.T.C.
                page 385 the Orissa High Court has held that if steel plates      G
                are cut to sizes, they cease to be the original product. What
                should be considered is whether those leather splits are
                commercially understood as dressed hides and skins. If
                they are understood only as just skins as claimed, there is
                no ne.ed to call them as splits in commercial parlance. The
                Courts have repeatedly ruled that the entries in the Act          H
    450                   SUPREME COURT REPORTS             [1989) 1 S.C.R.

A               should be treated only as understood by the Trade. These
                splits were produced before the Board at the time of hear-
                ing. They were found to be thin pieces which can be utilised
                only for miscellaneous purposes. The contention that these
                leather splits continue to be dressed skins and are declared
                goods of interstate importance, is untenable. The assessing
B               officer was therefore right in treating these splits as scraps
                and taxing them at the multipoint rate, and in the absence
                of 'C' forms, at 10%.

                      As regards the coloured skins, once the dresed skins
                bought are split and the upper layer of uniform size is
c               coloured or dyed, such coloured skins become different
                products. They are finished leather sold as coloured skim
                and not as dressed skins. They are commercially different,
                and are treated and dealt with in trade circles as different
                products. The process of dyeing or colouring changes the
                commercial nature of the dressed skins. There are different
D               patterns of dyeing and colouring. The complete piece may
                be dyed or coloured uniformly with a single colour or with a
                pattern of colours, depending upon the requirements of the
                prospective consumers in the market. As the dressed skins
                are subjected to process, first by splitting and secondly by
                colouring they become different products. Pieces of
E               coloured and dyed leather were produced before the Board
                at the time of hearing. Some pieces were coloured with a
                single colour on one side and dyed on the reverse. They can
                be used straightaway for manufacturing leather goods.
                They were also in patterns. The contention that no change
                is involved has therefore no force. Both the Appellate
F               Assistant Commissioner and the Assessing Officer were
                not therefore correct in allowing exemption."

          On the other hand, on behalf of the assessees, reference is made
    to certain circulars of the authorities which contain a contempo-
    raneous exposition of the meaning of the entry in question, reliance is
G   placed on the decision of the Sales Tax Appellate Tribunal to the
    contrary and it is emphasised that, to say that the one item is called
    scraps and the other is called leather is not sufficient to take them out
    of the description "hides and skins, in a raw or dressed state". It is
    submitted that cuttings of hides aµd skins do not cease to be hides and
    skins merely because they are small pieces and can be loosely des-
H   cribed as "scraps". So far as coloured leather is concerned, according
STATE OF TAMIL NADU v. MAHI TRADERS [RANGANATHAN, J.}                 451

to the assessee, the question is not whether the coloured skin is A
described as leather or whether it is a new product different from hides
and skins, as understood generally, but what exactly is the scope of the
expression used in entry (iii) of s. 14(1). The submission is that hides
and skins are generally described as leather even as soon as tanning is
done but the entry in the statute goes much beyond this stage. It takes
in all categories of hides and skins right from their raw condition, B
through various stages of their tanning and other processing, right
upto the stage when they receive the final finishing touches.

      We have heard learned counsel on both sides at length and come
to the conclusion that the assessees are entitled to the benefit of Ss. 14
and 15 of the CST Act in respect of the two items in question. As far as
the first item is concerned, it is common ground that leather splits are     c
nothing but cut pieces of hides and skins. We fail to see how they cease
to be hides and skins. It is no doubt true that they are cheaper and
have a separate name but the name only indicates that they are cut
pieces. It is not because they have ceased to be hides ahd skins and
constitute a different commercial commodity that they are called             D
'scraps'. Some of the dealers purchase and sell such splits and such
turnover is considerable. There is no material to suggest that they are
useless or worthless articles. A loose description of them as 'scrap'
cannot deprive them of the benefit of s. 14 of the Act.

      Turning to coloured leather, we may, at the outset, refer to a         E
very important circumstances referred to by the respondents. When
the CST Act came into force on 1.4.1957, a question was raised regard-
ing the meaning of the expression 'hides and skins in dressed state'
used ins. 14. The matter was referred to the leather development wing
of the Ministry of Commerce and Industry which gave the following
opinion:                                                                     F

            "Hides and Skins are obtained from either slaughtered or
            dead animals. The raw hides and skins thus obtained are
            known to be in the Green State. These are easily put-
            rescible; if proper precautions are not taken they would
            easily rot and decay. Since tanneries are not always located G
            very near the source of raw hides and skins, the question of
            preserving them for a temporary period till they reach a
            tanning centre assumes importance. Raw hides and skins
            are 'cured' by either wet salting, dry salting or drying. In
            the 'cured state' the raw maierials can be preserved for a
            temporary period. In the third state of temporary preserva- H
    452                   SUPREME COURT REPORTS              [1989] 1 S.C.R.

                tion, the hides and skins are 'picked'. During the next stage -...+
A
                they are tanned in which state they can be preserved almost
                indefinitely. These tanned hides and skins are processed
                further to yield Dressed Hides and Skins which are ready
                for use. 'Dressed' or finished material could also be pre-
                served almost indefinitely.
B
                      From the above, it will be seen that the expression        .~
                'Hides and Skins in the raw or dressed State' refers at one
                end to the raw material obtained from the slaughtered or
                dead animals and at the other end to the tanned and
                finished material; the expression, therefore, seems to
                include the other intermediate stages indicated in the pre-
c               vious paragraphs. Dressing, according to the authoritative
                interpretations, would mean the conversion of tanned
                hides and skins by further suitable processing into leathers
                of different types which are ready for use" (vide SBT/
              . 18(495/14) of November 11, 1957).
D
           It would seem though this is not quite clear from the record, that
    this ppinion held the field for quite some time until the assessments
    presently in question were made. Even here, as pointed out by the
    High Court, the departmental view was not quite consistent. The
    Deputy Commercial Tax Officer, in some of the cases, was willing to
E   concede that coloured leather, notwithstanding the colouring, con-
    tinued to be dressed hides and skins but thought that leather splits
    should be brought to multipoint tax. The Assistant Commissioner, on
    the contrary, took the view that splits would continue to be hides and
    skins. It was the Board of Revenue that decided that both items would
    fall outside the purview of item (iii) in section 14(1).
F
        It has been pointed out by this court in Desh Bandhu Gupta and
  Ors. v. Delhi Stock Exchange, [1979] 4 SCC 565, and Varghese v. ITO,
  [1981] 131 ITR 597 that a contemporaneous exposition by the
  administrative authorities is a very useful ·and relevant guide to the
  interpretation of the expressions used in a statute. Considering that
G the above clarification was sought for at the earliest point of time when
  a doubt arose as to the scope of the expression used by the statute and
  given after considering the technicalities of the processes employed in
  the manufacture of finished leather by the department fully conversant
  with this branch of trade and in the context of the provisions of this
  very statute, the terms cff the statute can well be construed by
H reference to such exposition, in the absence of anything in the statute
STATE OF TAMIL NADU v. MAHI TRADERS [RANGANATHAN, J.[               453

to indicate the contrary. Indeed, "such interpretation should be shown A
to be clearly wrong before it is overturned."

      Can it then be said that the view expressed above is clearly
wrong? We think not; on the contrary, it is seen to be quite correct.
The.statutory expression refers to "hides and skins in a dressed state".
The guidelines issued for identification of 'finished' leather for exports B
by the Indian Standards Institution (ISI) refer to as many as 19 opera-
tions or processes undergone during manufacture of 'finished leather'
but 'dressing' is not one of them. A glossary of terms relating to hides,
skins and leather published by the LS.I. in 1960 contains the following
definitions:

            CRUSTS: (Crust Leather)-Tanned hides and skins with-
                                                                          c
            out any finish.

            CURRYING: A series of dressing and finishing processes
            applied to leather after tanning in the course of which
            appropriate amounts of oils and greases are incorporated in D
            the leather to give it increased tensile strength, flexibility
            and resisting properties.

            DRESSED RIDES: Tanned hides, curried or otherwise
            finished, for vari'?us purposes, such as belting, harness and
            saddlery, travel goods and for upholstery.                    E

            DRESSING LEATHER: Vegetable tanned hides which
            may be dressed to suit the purpose for which they are to be
            used, such as for harness, saddlery and other mechanical
            purposes.
                                                                          F
            LEATHER: The skin or hide of animals prepared by
            tanning, which still retains its original fibrous strµcture
            more or less intact, but from which hair or wool may or
            may not have been removed and which has been treated so
            as to be imputrescible even after treatment with water.
                                                                          G
      The earlier glossary of such terms published by the British
Standards Institution defines 'dressing' as a "general term for the
series of processes employed to convert certain rough tanned hides
and skins and/or crust· leather into leather ready for use." Also,
"Leather" is defined as "a general term for hide or skin which still
retains its original fibrous structure more or less intact, and which has H
    454                    SUPREME COURT REPORTS             [1989] 1 S.C.R.

    been treated so as to be imputrescible even after treatment with
A
    water." The hair or wool may or may not have been removed. Certain
    skins, similarly treated or dressed, and without the hair removed, are
    termed 'fur'. The Dictionary of Leather Terminology published by the
    Tanners' Council of America, describes leather as "the hide and skin
    of any animal or any portion of such skin, when tanned, tawed or
B   otherwise dressed for use."

          The above definitions show that hides and skins acquire the
    name of 'leather', even if the hair or wool has not been removed
    therefrom, as soon as they receive some treatment which prevents
    them from putrefaction after treatment with water. Dressing is a stage
    much later than tanning. Indeed, from the definitions quoted above, it
C   will be seen that it is practically the same as giving finishing touches to
    the leather and making it suitable for the manufacture of particular
    types of goods.                                                               )c

       Sri Sen invited our attention, apart from the contemporaneous
D exposition by the Department, to the findings of the Tribunal in this
  regard in an earlier case which had not been appealed against by the
  Department. The Tribunal had said:

                ''We have carefully considered the records as well as the
                arguments. We have seen the specimens of the articles
E               sold. Bits of the same are also on record. We have carefully
                scrutinised the same. We are unable to say that what the
                appellants had sold is not leather or in other words dressed
                hides and skins. The fact that the appellant has done some
                more finishing would not take away the resultant product
                from the classification. We do find that the clarification
F               issued by the Board of Revenue, Madras and the Govt. of
                India supports the appellants case. The expert opinion
                which only says that the resultant product has undergone
                some chemical changes observed as under:

                        It is, surely a different product, because it is a
G               finished leather. It however, retains the leathery properties
                of the dressed leather.

                Hence the expert opinion also fully supports the appellants
                case inasmuch as it concedes that the resultant product is
                'finished leather'. It is because the issue in appellant's case
H               is not whether the appellant was selling a different product
           STATE OF TAMIL NADU v. MAHI TRADERS IRANGANATHAN, J.I               455
    .,.               from the one it purchased, but whether the appellant was
                                                                                    A
                       selling tanned leather. In this case, we do not find any
                       factual basis even to cast any doubt upon the appellant's
                      claim. It is a pity that the assessing authority should have
                      followed the audit objections without the application of his
                      own mind. Leather from the stage of raw skins to the stage
    ~                 of dressed hides and skins may undergo various stages of B



~··
                      changes.' Under the classification for the purposes of sec-
                      tion 14 of the Central Sales Tax Act, the various stages are
                      irrelevant. For the purposes of Tamil Nadu General Sales
                      Tax Act, 1959, only two stages that are relevant are the
                      skins anhe raw stage and the skins in the form of dressed
                      hides and skins (or tanned hides and skins). The appellant
                      purchases semifinished leather and undertakes further pro-
                                                                                    c
                      cess of finishing with a view to colour the hides and skins
                      for certain uses of skins. He says that he purchased the
                      same tanned hides and skins and sold the tanned hides and
                      skins. According to him the products purchased and sold
                      are not different even under the classification by way of the D
                      dichotomy between raw and dressed hides and skins under
                      the Tamil Nadu General Sales Tax Act. Under the Central
                      Sales Tax Act, the appellant is in a much better position,
                      because all the hides and skins are brought together in one
                      entry. Whether raw or dressed, the product falls under the
                      same entry."                                                  E

          We are of opinion that this represents the correct view of the scope of
          the entry in question.



•
 '..l
                The same conclusion is further borne but by the literature refer-
          red to before us by Sri Ramachandran. Vol. 7 of the Encyclopaedia          F
          Brittanica, under the word "dress", explains that the verb has various
          applications which can be deduced from its original meaning and that
          "it is thus used not only of the putting on of the clothing but of the
          preparing and finishing of leather ....... "Vol. 17, under the head
          "leather" details the various processes applied in the treatment of
          hides and skins at all stages, pre-tanning, tanning and post-tanning.      G
)         Dyeing or colouring is a process which follows tanning but precedes
          "finishing" (i.e. dressing) in order to make it suitable for the purpose
          for which it is required in commercial usage. Part V of the "Wealth of
          India", a publication of the Council of Scientific and Industrial
          Research (1966), dealing with leather under "Industrial Products" ex-
          plains that "hides and skins are liable to putrefaction and loss unless    H
    456                   SUPREME COURT REPORTS            [1989] 1 S.C.R.

  suitably treated and converted into leather." Structurally, hides and
A
  skins have a thick middle layer called corium, which is converted to
  leather by tanning. The operations involved in leather manufacture
  however fall into three groups. Pre-tanning operations include soak-
  ing, liming, deliming, bating and pickling, and post tanning operations
  are splitting and shaving, neutralising, bleaching, dyeing, fat-liquoring
B and stuffing, setting out, samming, drying, staking and finishing.
  These operations bring about chemical changes in the leather sub-
  stance and influence the physical characterstics of the leather, and
  different varieties of commercial leather are obtained by suitably
  ad justing the manufacturing operations. These processes need not be
  gone into in detail but the passages relied upon clearly show that hides
  and skins are termed 'leather' even as soon as the process of tanning is
c over and the danger of their putrefaction is put an end to. The entry in
  the CST Act, however, includes within its scope hides and skins until
  they are 'dressed'. This, as we have seen, represents the stage when
  they undergo the process of finishing and assume a form in which they
  can be readily utilised for manufacture of various commercial articles.
D In this view, it is hardly material that coloured leather may be a form
    of leather or may even be said to represent a different commercial
    commodity. The statutory entry is comprehensive enough to include the
    products emerging from hides and skins until the process of dressing or
    finishing is done.

E          We are, therefore, of the view that the High Court was right in
    holding that 'splits' and 'coloured leather' continue to be hides and
    skins eligible for special treatment under the CST Act. All the appeals,
    therefore, fail and are dismissed. We however make no order as to
    costs.

F   G.N.                                                Appeals dismissed.