JUDGMENT

BALAKRISHNA ERADI, J.:— The short but interesting question that arises for our consideration in this appeal by special leave is whether the Compressed Woollen Felts manufactured in the small-scale industry unit of the appellants can be said to constitute "cloth" so as to fall within the scope of Entry 6 of Schedule I of the Madhya Pradesh General Sales Tax Act, 1958 (for short the Act), which is in the following terms :-

"All varieties of cloth manufactured in mills or on powerlooms or handlooms including processed cloth. but excluding hessian cloth" - so as to be eligible for exemption of sales-tax under Section 10 of the said Act.

2. The process of manufacture of felt adopted in the appellants factory has been described in the order of the Commissioner of Sales-tax dated January 25, 1983. The raw material consisting of woollen fibres is first mixed thoroughly and thereafter carded on a carding machine, which process results in the laying of the fibres in a combed condition in a uniform direction. The combed fibres in the shape of a web layer are then subjected to the process of hardening in a machine having an eccentric motion; the carded webs are put through two layers of