The petitioner manufacturers aluminium in its factory situated at Renukoot, from bauxite by subjecting it to electrolytic processes. The aluminium produced by the petitioner, according to the petitioners case, fall in three categories, i. e. , cast products, rolled products and extrusions (see annexure C to the amendment application ). The process adopted for manufacturing these products as set out by the petitioner is this. Alumina is extracted from bauxite and is then subjected to electrolytic processes in the potrooms. The alumina in the potrooms is in the shape of molten metal. This molten metal is fed into cast iron moulds and aluminium ingots and aluminium alloy ingots are produced. By the same process of casting, wire bars and properzi redraw rods are also produced. The process for making wire bars, as stated, is by pouring the molten metal in casts and then chilling it directly. So far as properzi redraw rods are concerned, the process is as follows : Molten metal is poured directly from potroom crucible in the melting furnace and then transferred to holding furnace. It is then degassed, fed through a cast iron spout into the groove of a water-cooled circular steel casting wheel, which rotates at a slow speed. The top portion of the grooved steel mould is covered by a steel belt and during one half rotation of the casting wheel, the metal gets solidified and comes out in the form of a continuous bar of about 12 sq. centimeter cross-section at a temperature of 440 degrees to 480 degrees centigrade. This bar is fed through a 13 strand properzi mill where the area of cross-section is progressively reduced and finally 9. 5 mm. dia redraw rods come out which are wound in the drum of a mechanical coiler. So far as rolled products are concerned, they consist of hot rolled plates, hot rolled coil and cold rolled sheet/coil and corrugated sheets, etc. The hot rolled plates/coils are produced by using rolling ingots, which are cast by direct chill (D. C.) casting process. The ingots are scaled to smoothen the surface, heated in soaking pits and then rolled in a reversing hot mill to the required thickness. The method of making cold rolled sheets/coils is by rolling the hot mills product on a reversing cold mill to fine thickness according to requirements of the ultimate manufacturer. Slug stock is produced by rolling of hot mill product on sheet mill to the required thickness and shearing it to desired widths in shearing machine. Circles are produced by using cold mill sheets which are cut to desired diameters on circle cutting machine and purchased by utensil manufacturers. Corrugated sheets are produced by using cold mill sheets, and passing them through the roll corrugating machine. Extrusions are produced in the form of rods, bars, flats, squares, hexagonals, angles, channels, tees, I beams, tubes, round, oval, square, rectangular, triangular and other solid and hollow shapes. The process of manufacturing extrusions is by using a preheated billet in an extrusions press, and forcing it through a die orifice of the desired shape and size by a hydraulically operated ram, when the desired extruded shape comes out on the run out table.

The State Government issued Notification No. ST-II-6628/x - 1012-1972 dated 1st December, 1973, in exercise of its powers under sub-section (2) of section 3-A of the U. P. Sales Tax Act ordering that with effect from 1st December, 1973, the turnover in respect of particular goods "including all kinds of minerals and ores, metals and alloys except copper, tin, zinc, nickel or alloy of these metals only" would be taxable at all points of sale at 3 1/2 per cent. This was followed by another Notification No. ST-II/4949/x - 10 (2)-7 dated 30th May, 1975, whereby the State Government imposed tax at the rate of 2 per cent. at the point of sale by the manufacturer or importer on "all kinds of minerals, ores, metals and alloys, except those included in any other notification issued under the Act".