ORDER

1. The appeals, by certificate, arise upon the common judgment of a Division Bench of the Kerala High Court whereby writ petitions filed by the respondents were allowed.

2. The respondents were sellers of Caristrap Rayon Cord Strapping. According to them, the said strapping was exempted from taxation under the Kerala General Sales Tax Act, 1963. They relied in this behalf upon Entry 7 of Schedule III to the said Act. Schedule III sets out the goods which are exempted from sales tax under Section 9 of the said Act. Entry 7 thereof reads thus:

"Cotton fabrics, woollen fabrics and rayon or artificial silk fabrics as defined in Items Nos. 19, 21 and 22 respectively of the First Schedule to the Central Excises and Salt Act, 1944."

3. Item 22 of the First Schedule to the Central Excises and Salt Act, 1944, so far as it is relevant, read as follows:

"Rayon or Artificial Silk Fabrics.- Rayon or artificial silk fabrics include all varieties of fabrics manufactured either wholly or partly from rayon or artificial silk."

4. The said strapping, according to the writ petitions, is a fabric made purely from rayon yarns. The rayon yarns are used with bonding agents in fabricating the said strappi