JUDGMENT

B.P. Jeevan Reddy, J.

1. The question in this appeal is whether VIP suitcases are plastic articles within the meaning of Entry 113 of Schedule I to the Andhra Pradesh General Sates Tax Act. The question arises with reference to the assessment year 1981-82. With effect from 1-7-1985 a new entry, viz., Entry 163 was introduced in Schedule I expressly taking in all kinds of suitcases and simultaneously amending Entry 113. Prior to 1-7-1985, there was no entry dealing specifically with suitcases. Entry 113 read as follows: "Plastic sheets and articles" and the rate of tax was 6%. In the year 1983, the rate of tax was increased to 9%. The amended Entry 113 (w.e.f. 1-7-1985) reads as follows: "Plastic sheets and articles excluding those allied goods falling under any other item" whereas Entry 163 reads:

"All kinds of suitcases, briefcases and vanity bags."

2. The appellant is a dealer inter alia in VIP suitcases. Suitcases are made of leather, cloth, rexine and other material. We are concerned herein with suitcases made of plastic by the method known as "injection-moulding" and fitted with steel bands, locks and ancillaries made of other materials. The appellant submitted that the