SETHURAMAN, J.

The Deputy Commissioner of Commercial Taxes has applied for revision of the order of the Sales Tax Appellate Tribunal, dated 11th July, 1974. The assessee was originally assessed on a taxable turnover of Rs. 21, 589.42 for the assessment year 1968-69 by an order dated 18th February, 1970. Subsequently, this assessment was revised and a turnover of Rs. 24, 726.75 was brought to tax at multi-point rate on the ground that galvanised plain sheets, referred to as G.P. sheets and C.R. sheets, were wrongly exempted treating the goods as single point goods. Reassessment was made on 16th August, 1972, and the matter was taken on appeal to the Appellate Assistant Commissioner. He also held that G.P. sheets were liable to tax at multi-point rate. The assessee took the matter on appeal to the Appellate Tribunal, disputing the levy of tax at 3 per cent on Rs. 15, 143.23 pertaining to G.P. sheets. The contention of the assessee was that these sheets came within the category of iron and steel falling under item 4 of the Second Schedule to the Tamil Nadu General Sales Tax Act and he relied on a decision of the Andhra Pradesh High Court in State of Andhra Pradesh v. Sri Durga Hardware Stores. The Tribunal accepted the assessee's contention and held that the relevant goods should be considered as single point goods falling under item 4 of the Second Schedule. The assessment was directed to be modified accordingly. It is this order of the Tribunal that is now brought on revision to this Court.

The only question that arises for consideration is whether G.P. sheets fall within the category of iron and steel. The Supreme Court in State of Tamil Nadu v. Pyare Lal Malhotra considered the scope of entry No. (iv) in section 14 of the Central Sales Tax Act which is the same as the corresponding entry No. 4 in the Second Schedule to the Tamil Nadu Act. In that case, the main question was whether the expression "that is to say" was illustrative or exhaustive. The Supreme Court pointed out that the expression "that is to say" was exhaustive and that what was meant was "iron and steel goods of various types enumerated below". Therefore, in order to fall within the category of goods described in entry 4 of the Second Schedule, it is necessary that is must be brought within one or the other of the entries therein. Sub-item (d) of item 4 contains reference to "steel plates". Galvanised plates are, according to the assessee, only steel plates described in the said entry. We have to examine the correctness of this contention.It is necessary first to point out what galvanisation means. In current terminology the sheets are called galvanised sheets. But in olden days, they were used to be called "zinc sheets". The process of galvanisation has been described in McGraw-Hill Dictionary of Scientific and Technical Terms as follows :

"To deposit zinc on the surface of metal by the processes of hot dipping, sherardizing, or sometimes electroplating."

The word" sherardizing"means, according to the same dictionary :

" Coating iron with zinc by tumbling the article in powdered zinc at about 250-375 degree C." *

The category of goods called galvanised plain sheets have acquired a different commercial quality as a result of the process of galvanisation. Before galvanisation, they are merely plain iron sheets. But subsequent to the galvanisation they have acquired a quantity of zinc which has become part and parcel thereof. Though the sheet cannot be called as alloy of iron and zinc, still the iron or zinc has become shrouded with the other. The zinc cannot be separated or rubbed off like paint. The result is the sheet acquires a new commercial character.

In a judgment of the Gujarat High Court in State of Gujarat v. S. V. Motichand, Lunawada the dispute to be dealt with related to corrugated iron sheets. At page 300, it was stated, after reference to the Encyclopaedia Britannica, Fourteenth Edition, Volume 6, at page 471, that the process of corrugation