ISMAIL, J.

This is a petition preferred by the State against the order of the Sales Tax Appellate Tribunal (Additional Bench), Coimbatore, dated 1st August, 1972. The controversy lies within a narrow compass. The goods dealt with by the respondent were nitro phosphate manufactured by the Fertiliser Corporation of India Ltd. It contained 16 per cent nitrate and 18 per cent phosphate. The controversy was, whether nitro phosphate was liable to single point tax, falling under entry 21 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, herein referred to as the Act or not. The said entry at the relevant time was as follows :

"21. Chemical fertilisers, that is to say, - (1) ammonium sulphate, (2) ammonium nitrate, (3) urea, (4) ammonium chloride, (5) sodium nitrate, (6) calcium ammonium nitrate, (7) super-phosphate single, (8) super-phosphate triple, (9) kotka phosphate, (10) di-calcium phosphate, (11) potassium chloride (muriate of potash), (12) sulphate of potash, (13) mono-ammonium phosphate, (14) di-ammonium phosphate, (15) bone-meal, (16) any mixture of one or more of the articles mentioned in items (1) to (15) and one on more of the organic manures."

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