GOPALAN NAMBIYAR, C.J.

These tax revision cases relate to the claim for exemption from sales tax under the Kerala General Sales Tax Act, 1963, in respect of the turnover on sales of "P.V.C. cloth" (Rexine). T.R.C. No. 61 of 1976 relates to the year 1971-72 and the claim is in respect of an amount of Rs. 1,33,840.34; T.R.C. No. 62 of 1976 is in respect of 1972-73 and the claim is for Rs. 1,56,181.04. The genesis and the statutory background of the claim is as follows :

Under article 286(3) of the Constitution of India :

"Any law of a State shall, in so far as it imposes, or authorities the imposition of, a tax on the sale or purchase of goods declared by Parliament by law to be of special importance in inter-State trade or commerce, be subject to such restrictions and conditions in regard to the system of levy, rates and other incidents of the tax as Parliament may by law specify."

In accordance with the above constitutional provision, the Central Sales Tax Act, 1956, was passed by Parliament. Section 14 declared goods of special importance in inter-State trade or commerce. Sub-clause (iia) of the said section is :

"Cotton fabrics, as defined in item No. 19 of the First Sch