S.K. Mal Lodha, J.—The Board of Revenue for Rajasthan, Ajmer (The Board, herein) has referred the following question of law for our deci-sion:- "Whether on the facts and circumstances of this case the galvanised currugated sheets come within the definition of iron and steel for the relevant assessment period ?" 2. The dealer-assessee (respondent) was assessed by the C.T.O. Pali (Assessing Authority) in resect of the year 1964-65 u/s 10 of the Rajasthan Sales Tax Act (No. XXIX of 1954) (for short the Act herein) and held that the sale of galvanised corrugated sheets were liable to tax at general rate for the relevant assessent period. The dealer-assessee was unsuccessful in appeal. A revision was filed before the Board. The Board by its order dated September 18, 1974 held that the sale of galvanised corrugated sheets are taxable @ 2% and not @ 6% as decided by the Assessing Authority and the Deputy Commissioner, (Appeals) Commercial Taxes, Jodhpur, in appeal. It was further held that the excess tax of 4% charged, if collected, be refunded to the dealer. The Board while doing so relied on M/s. Radha Ballabh & Sons vs. State of Rajasthan (1) which is a decision rendered by the three learned Members of they Board. According to the Board the galvanised corrugated sheets fall within the definition of Iron and Steel within the meaning of Sec. 14 of the Central Sales Tax Act (No. 74 of 19.6) hereinafter to be referred as the C.S.T. Act). An application for reference under section 15 (1) of the Act was filed by the Assessing Authority. The Board thought it proper to make a reference to this Court for deciding the question aforesaid. 2. We have heard Mr. A.K. Mathur, learned counsel for the Assessing Authority. No body has appeared on behalf of the dealer-assessee. 3. The only question which we are called upon to decide is whether in the case on hand the galvanised corrugated sheets come within the definition of "Iron and Steel" in respect of the relevant assessment period. 4. 2. We have heard Mr. A.K. Mathur, learned counsel for the Assessing Authority. No body has appeared on behalf of the dealer-assessee. 3. The only question which we are called upon to decide is whether in the case on hand the galvanised corrugated sheets come within the definition of "Iron and Steel" in respect of the relevant assessment period. 4. The relevant portion of Sec. 14 of the C.S.T. Act as it stood at the relevant time reads as under:- "It is hereby declared that the following goods are of special importance in inter-State trade or commerce:- (i) coal, including coke in all its form; (ii) cotton, that is to say, all kinds of cotton (indigeneous or imported) in its unmanufactured state, whether ginned or unginned, baled, pressed or otherwise, but not including cotton waste; (iii) hides and skins, whether in a raw or dressed state; (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, (ii) steel sheets, sold in the same form in which (iii) sheet bars and tin bars, they are directly (iv) rolled steel sections produced by the (v) tool alloysteel; rolling mill; 5. A Division Bench of the Board in the case of M/s. Raj. Iron & Steel Merchants Assn., Pvt. Ltd .Jaipur vs. State (2) observed as follows:- "We find that all these items of CP & GC sheets and CI wires have one thing in censur is that they are all galvanised i.e. they are galvanised plain sheets and galvanised corrugated sheets, and galvanised I. wires. As corrugation is only a change in the shape of sheet, it does not really change the property of the matter and as the main point at issue remains, whether galvanisation does make any fundamental difference in the nature of the item. In the Chambers Twentieth Century Dictionary, galvanised iron is defined as iron coated with zinc. It would, thus be seen that galvanisation is the process by which sheets or wires of iron get a continuing of zinc. In the Chambers Twentieth Century Dictionary, galvanised iron is defined as iron coated with zinc. It would, thus be seen that galvanisation is the process by which sheets or wires of iron get a continuing of zinc. In our opinion, such a process where the entire metal area of the iron item is coated with another metal (zinc) in the present case there occurs a basic change in the nature and properties of the iron sheets or wires, and accordingly after this process of galvanisation, they could not be strictly called merely items of Iron & Steel. I view of this position, we find that it has been rightly held that galvanised plain sheets or galvanised corrugated sheets or galvanised I, wires, no longer fall under the category of Iron & Steel u/s. 14 of the Central Sales Tax Act and as notified vide Government Notification dated 2.3.63. Thus, they attract sales tax at the rate of 6% instead of 2%". 6. The Board held that CP and GC sheets and CI wires are liable to sales tax at the rate of 6%. In that case the assessment year was 1963-64 and the accounting period was from 1.4.63 to 31.3.64. In M/s Radha Ballabh & Sons case (supra) the Larger Bench of the Board did not subscribe to the view taken in the Rajasthan Iron & Steel Merchants case (supra). As there was no decision of the reference made to this Court, the Board referred the matter to a Larger Bench. The question in M/s Radha Ballabh & Sons case (supra) was whether galvanised corrugated sheets fall within the term "iron and steel" occurring in Sec 14 (iv) of the C.S.T. Act as it then stood and it opined that galvanised corrugated sheets fall under the definition of iron and steel within the meaning of Sec 14 (iv) of the C.S.T Act and galvanisation or corrugation does not effect their basic charactor as iron and steel. As a necessary consequence of that the Larger Bench in M/s. Radha Ballabh and Sons case (supra) was of the view that the later view of the two Division Benches of the Board opining that by process of galvanising the iron sheets do not lose their basic character and they stitl fall within the term iron and steel under s. 14 (iv) of the C.S.T. Act is the sund view and it dissented with the view taken in M/s. Raj Iron a Steel Merchants case (supra). Here we may mention that in coming to the aforesaid conclusion, the Board, inter-alia, noticed the cases of State of Gujarat vs. Shah Valjibhai(3), Algu Ram Harinarayan Ram vs. A.C.S.T. Cuttak (4), Hukamchand Mahendra Kumar vs. Commissioner of Sales Tax (5), C.G.T.U.P. Vs. Agrawal Commercial Corp. (6) and State of A.P. Vs. Sri Durga Hardware Stores (7). 7. It relied on State of A.P.s case (supra) in which it was held : "that galvanised plain or corrugated sheets and B.P. sheets fall within the ambit of "Iron and Steel in entry 2 of the Third Schedule to the Andhra Pradesh Central Sales Tax Act." 8. The entry No. 2 in that Act was in parimoteria with Sec. 14 (iv) of the C.S.T. Act as it stood before the amendment. 9. The Larger Bench of the Board agreed with the view taken in the case of State of A.P.s case (supra). 10. It is the correctness of the decision of the Larger Bench of the Board reported in M/s Radha Ballabh & Sons case (supra) that precisely comes up for our consideration while answering the question referred to us. For this purpose we will only confine ourselves in noticing the cases of State of A.P.s case (supra), State of Tamil Nadu vs. Pyare Lal Malhotra (8) and Dy. Commissioner vs. Mohammed Ibrahim Narakuyar Sons (Madras) (9). 11. We may state atonce that State of A.P.s case (supra) is no more a good law in view of State of Tamil Nadus case (supra) by which was reversed. 12. Commissioner vs. Mohammed Ibrahim Narakuyar Sons (Madras) (9). 11. We may state atonce that State of A.P.s case (supra) is no more a good law in view of State of Tamil Nadus case (supra) by which was reversed. 12. In State of Tamil Nadus case (supra) the scope of Sec. 14 (iv) of C.S.T. Act was examined in connection with the term "iron and steel" in respect of "steel rounds, flates, angles, plates, bars" or similar goods in other forms and shapes and the question arose whether they could be taxed again even if the material out of which they were made had already been subjected to sales tax once as iron and steel scrap. The expression that is to say used in S. 14 (iv of the C S.T. Act was considered and their Lordships have observed as follows: ordinarily, the expression "that is to say" is employed to make clear and fix the meaning of what is to be explained or defined, Such words are not used, as a rule, to emplify a meaning while removing a possible doubt for which purpose the word includes is generally employed. In unusual cases, depending upon the context of the words "that is to say", this expression may be followed by illustrative instances". But, in the context of single point sales tax, subject to special conditions when imposed on separate categories of specified goods, the expression was apperantly meant to exhoustively enumerate the kinds of goods on a given list. The purpose of an enumeration in a statute dealing with sales tax at a single point in a series of sales would, very naturally, be to indicate the types of goods each of which would constitute a separate close for a series of sales. Otherwise, the listing itself loses all meaning and would be without any purpose behind it". 12. After considering some of the terms, their Lordships have expressed themselves in the following words:- "We, however, prefer the more natural and normal interpretation which follows plainly from the fact of separate specification and numbering of each item. This means that such item so specified forms a separate species for each series of sales although they may all belong to the genus; iron and steel. This means that such item so specified forms a separate species for each series of sales although they may all belong to the genus; iron and steel. Hence, if iron and steel "plates" are melted and converted into wire and then sold in the market, such wire would only be taxable once so long as it retains its identity as commercial goods belonging to the category "wire" made of either iron or steel. The mere fact that the substance or raw material out of which it is made has also been taxed in some other form, when it was sold as a separate commercial commodity, would make no difference for purposes of the law of sales tax. The object appears to us to be to tax sales of goods of each variety and not the sale of the substance out of which they are made". 13. The Supreme Court, therefore, concluded that the expression iron and steel, used in cl. (iv) of Sec. 14 of the C.S. T. Act. and the categories specified therein are exhoustive. 14. Before a Division Bench of the Madras High Court in Dy. Comis-sioners case (9) a question arose whether the galvanised plain sheets, are iron and steel and liable to be taxed at the multi-point rate in accordance with the entry 4 of the Second Schedule to the Tamil Nadu General Sales Tax Act, (No. 1 of 1939). 15. The learned Judges examined the meaning of galvanised plain sheets and after referring to State of Tamil Nadus case (supra) held that galvanised plain sheets, referred to as C.P. sheets or C.R. sheets would not fell within the category of iron and steel under entry 4 of the Second Schedule to the Tamil Nadu General Sales Tax Act, 1959 as it stood during the assessment year 1958-59 and therefore, they are taxable at multi-point rate. The reason given in support of the aforesaid conclusion by the learned Judges is that galvanised plain sheets were previously known as zinc sheets and merely because a different expression has come to be used it does not mean that they retain the character of iron and steel plates as they are actually materials different from steel, plates and their use is also different, and commercially they are different goods. The learned Judges dissented from the view taken in State of A P.s case (supra) and stated that it was taken at a time when the decision in State of Tamil Nadus case (supra) by the Supreme Court had not been rendered. The learned Judges did not subscribe to the view taken in A.P.s case (supra) also as the reasoning given was that galvanication was nothing but meeting the iron sheet with zinc by an electrical process or some other process, to prevent it from oxidation and galvanisation improved the utility of the raw material of iron. The reasoning given in Tamil Nadus case (supra) was adopted for coming to the conclusion that the turnover in that case was liable to be taxed at the multipoint rate. 16. We agree with the view taken in Deputy Commissioners case (supra) and are of opinion that the reasoning given in A.P.s case (supra) is no more available to the dealer assessee for holding that the galvanised corrugated sheets, come within the definition of iron and steel in respect of the assessment year 1964 65. 17. It is clear from State of Tamil Nadus case (supra) that the ordinary meaning to be assigned to a taxable item in a list of specific items is that each item so specified should be considered as a separately taxable item for purposes of single point taxation in a series of sales unless the contrary is shown. It was also held therein that the mere fact that the substance or raw material out of which it is made has also been taxed in some other form when it was sold as a separate commercial commodity, would make no difference for purposes of the law of sales tax It has authoritatialy been laid down by the Supreme Court in the aforesaid decision that the object is to tax sale of each commercial commodity and not the sale of the substance out of which they are made and that each comm-arcial commodity becomes a separate object of taxation in a series of sales of that commercial commodity so long as it retains its identity as that commodity. Galvanised corrugated sheets are actually different from the material of iron and steel of which they are made, their use is also different and they are commercial goods. For all these reasons, the view taken in Dy. Galvanised corrugated sheets are actually different from the material of iron and steel of which they are made, their use is also different and they are commercial goods. For all these reasons, the view taken in Dy. Commissioners case (supra) appears to be sound and we respectfully follow it. We would like to state here that the contrary view taken in M/s. Radha Vallabh & Sons case (supra) and the two later Division Benches of the Board after M/s Raj. Iron and Steel Merchants Case (supra) is not correct as it is not according to the decision in State of Tamil Nadus case (supra). 18. For the aforesaid reasons, the order of the Board dated September 18, 1974 holding that the sale of galvanised corrugated sheets are taxable @ 2% and not @ 6% for galvanised corrugated sheets are not iron and steel within the meaning of Cl (iv) of S. 14 of the C.S.T. Act is erroneous. In our opinion, the galvanised corrugated sheets do not come within the definition of iron and steel for the relevant assessment period. 19. We, therefore, answer the question stated hereinabove in the negative and in favour of the Department Assessing Authority and against the dealer-assessees (respondent). 20. We leave the parties to bear their own costs of this reference. 21. The Office shall take action in accordance with Sec. 15(5) of the Act.