( 1 ) THIS is the Commissioners revision under Section 11 (1) of the U. P. Sales Tax Act relating to the assessment years 1971-72 and 1972-73 and the question for consideration is as to whether steel tubes are liable to tax as a declared commodity under Section 14 (iv) of the Central Sales tax Act, 1956, at the rate of 3 per cent or as mill stores liable to tax at 6 per cent. The only reason given by the revising authority for treating steel tubes as a declared commodity under section 14 (iv) of the Central Act was that in the revision for the immediately preceding year this commodity has been taxed at 3 per cent. This view is wholly erroneous and cannot be sustained.

( 2 ) SECTION 14 of the Central Act declares certain goods to be of special importance in inter-State trade or commerce. Clause (iv) of this section as applicable to the assessment year under consideration was as under :

(iv) Iron and steel, that is to say, (a) pig iron and iron scrap; (b) iron plates sold in the same form in which they are directly produced by the rolling mill; (c) steel scrap, steel ingots, steel billets, steel bars and rods; (d) (i) steel plates, } sold in the same form in (ii) ste