ISMAIL, C.J.

The only question that the Tribunal had to decide was whether absorbent cotton wool produced by the petitioner herein could be classified under the heading "surgical dressing" under item 95 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959

"Drugs, patent or proprietary medicines as defined in section 3 of the Drugs and Cosmetics Act, 1940 (Central Act XXIII of 1940), or medicinal mixtures or compounds, the components of which have not already suffered tax, but excluding Arishtams or Asavas and including surgical dressing."

Item 2 of the Second Schedule reads as under :

" Cotton, that is to say, all kinds of cotton (indigenous or imported) in its unmanufactured state whether ginned or unginned, baled, pressed or otherwise, but excluding cotton waste." *

It can be immediately seen that the petitioner's product, namely, absorbent cotton wool, cannot fall under item 2 of the Second Schedule to the Act, because for item 2 to apply, the cotton must be in an unmanufactured state. The petitioner's product had gone through some manufacturing processes. Therefore, item 2 of the Second Schedule cannot apply. The other question is whether it comes under i