JUDGMENT

PATHAK, J.:— The question raised in these appeals is whether the "Rayon Tyre Cord Fabric" manufactured by the appellant is a rayon fabric covered by item 18 of the Schedule to the Rajasthan Sales Tax Act, 1954, and therefore exempt from sales-tax under the Central Sales Tax Act.

2. The appellant owns an industrial unit, Shriram Rayons, situated at Kota in the State of Rajasthan. It manufactures a product described as "Rayon Tyre Cord Fabric". The appellant claims that the product falls within item 18 of the Schedule to the Rajasthan Sales Tax Act which exempts from sales-tax and purchase tax-

"All cotton fabrics, rayon or artificial silk fabrics, woollen fabrics as defined in the Additional Duties of Excise (Goods of Special Importance) Act, 1957 (Central Act 58 of 1957)."

Sec. 2 (c) of the Additional Duties of Excise (Goods of Special Importance) Act, 1957 declares that the expression "rayon or artificial silk fabrics" shall have the meaning assigned to it in Item 22 of the First Schedule to the Central Excises and Salt Act, 1944. Item 22 reads :-

" "Rayon or artificial silk fabrics" means all varieties of fabrics manufactured either wholly or party from rayon or artificial s