JUDGMENT The judgment of the Court was delivered by M. B. SHAH, J. - The Gujarat Sales Tax Tribunal has referred the following issue for our decision under section 69(1) of the Gujarat Sales Tax Act, 1969 (hereinafter referred to as "the Sales Tax Act") : "Whether, on the facts and circumstances of the case, the Tribunal was right in holding that side-strips sold by the applicant were not covered by the scope of entry 21 of Schedule II, Part A, or entry 6 of Schedule II, Part A, to the Gujarat Sales Tax Act, 1969 ?" At the time of hearing of this matter, the learned advocate for the applicant as well as the learned Assistant Government Pleader agree that the aforesaid issue requires to be reframed because it is not the contention of the applicant that the product which is considered by the applicant as side strips would be covered by entry 6 of Schedule II, Part A. The contention is that the product "side strips" produced by the applicant would be covered by entry 21 of Schedule II, Part A, and not by residuary entry 13 of Schedule III. Hence, the question is reframed as under : "Whether, on the facts and in the circumstances of the case, the Tribunal was right in holding that side strips sold by the applicant were not covered by entry 21 of Schedule II, Part A, to the Gujarat Sales Tax Act, 1969 ?" For deciding the aforesaid question, it would be necessary to refer to the facts as to how side strips are produced by the applicant. As such, side strips are not produced, but, admittedly, they emerge simultaneously with the production of metallic yarn from polyester sheets. The process of producing metallic yarn was witnessed by the Assistant Sales Tax Commissioner before deciding the appeal. He has noted that the metallic yarn is produced from a transparent glittering polyester film. Firstly, the film is put on rough slitting machine from which strips of the width of 64 mm. emerge. These strips are further placed on micro-slitting machine which cuts the strips into 214 pieces. These 214 pieces are known as metallic yarn. At that time both the sides of the strip are left out. These remaining strips are of uneven breadth and they are called side strips. emerge. These strips are further placed on micro-slitting machine which cuts the strips into 214 pieces. These 214 pieces are known as metallic yarn. At that time both the sides of the strip are left out. These remaining strips are of uneven breadth and they are called side strips. The Tribunal has further noted on the information furnished that polyester yarn which is used for weaving clothes is produced by three methods of which the basic raw material is the same. The side raw material is in pulp form and is known as D.M.T. which is a petroleum product out of which all polyester is manufactured. From this, yarn is produced by using either of the three different processes, viz., (i) fibre process, (ii) continuous filament process and (iii) metallic filament process. In the present case, the relevant process is metallic filament process. As per this process, pulp is spread like a sheet which is called polyester filament. This filament is given aluminium vapour on both the sides which gives it a glittering surface. After this, the film is put on rough slitting machine. Thereafter, the further process as noted by the Assistant Sales Tax Commissioner is followed. From the aforesaid process of manufacturing metallic yarn, it is clear that metallic yarn and side strips are produced out of the same substance which is known as polyester film. Firstly, the strips of width of 64 mm. from the polyester film are produced. Thereafter, the strips are placed on micro-slitting machine which cuts it into 214 pieces plus 2 side strips. The question is whether the said side strips would be covered by entry 21. In the background of the aforesaid facts, for deciding the question, we would first refer to entry 21 (as it stood at the relevant time) which is as under : Entry 21 in Schedule 11, Part A : "Staple fibre and staple fibre yarn, terylene fibre and terylene fibre yarn and all other synthetic fibres and synthetic yarns (other than those specified in any other Schedule) including waste thereof." Analysing the aforesaid entry, it would mean that it covers - (a) staple fibre and staple fibre yarn; (b) terylene fibre and terylene fibre yarn; and (c)(i) all other synthetic fibres and synthetic yarns (other than those specified in any other Schedule); (ii) including waste thereof. From the process of manufacturing metallic yarn noted above, it would be difficult to hold that side strips are the waste of synthetic fibres or synthetic yarns. They are not waste or left out of the yarn or fibre. At the most, it can be said to be a waste of metallic polyester film from which metallic polyester yarn is produced. Therefore, it is not possible to accept the contention that side strips would be covered by entry 21 as if they are waste of synthetic fibres or yarns. In this view of the matter, Mr. Joshi, learned advocate for the applicant, has not pressed the said contention further. However, the learned advocate for the applicant vehemently submitted that, considering the admitted facts on record, the Tribunal ought to have held that side strips produced by the applicant in this particular case are covered by the phrase "and all other synthetic fibres and synthetic yarns". He submitted that before the Assistant Sales Tax Commissioner it was pointed out that side strip is a yarn of 750 deniers and above. It is at the most a yarn of inferior quality, but at the same time it retains its quality as yarn. From the record and the discussion by the Tribunal, it is apparent that side strip which is sold by the applicant is a yarn having 750 deniers and above. The Tribunal has arrived at the conclusion that by and large it is used for preparing zalar, kinar (border), foomata (ornamental hangings), etc. The Tribunal has further noted that side strips are even used for weaving. May be, the use for weaving is nominal. From this finding, it can be held that side strips are used for weaving to some extent from which sari border or foomata or zalar are prepared. The only distinction between side strips produced by the applicant in the present case and yarn is with regard to their width. Admittedly, the width of side strips is around 4 mm. while the width of metallic yarn would be normally 1 mm. Considering these facts, in our view, side strips, which are product of metallic polyester film, would be covered by the comprehensive phrase "all other synthetic yarns" except staple fibre yarn and terylene fibre yarn. The words "all other" should be given its fullest amplitude so as to include all forms of synthetic fibres and synthetic yarn. Considering these facts, in our view, side strips, which are product of metallic polyester film, would be covered by the comprehensive phrase "all other synthetic yarns" except staple fibre yarn and terylene fibre yarn. The words "all other" should be given its fullest amplitude so as to include all forms of synthetic fibres and synthetic yarn. Hence, side strips produced by the applicant would be covered by entry 21. The Tribunal has not accepted the contention that the side strips would be nothing but a kind of metallic yarn itself mainly because - (i) it was raised for the first time before the Tribunal; and (ii) this conclusion is not acceptable on the facts of the case as side strips are distinct and different commercial commodities as described by the applicant. In our view, when the facts were admitted before the Tribunal, the Tribunal ought to have appreciated the contention on the basis of the admitted facts. Further, the Tribunal held that side strips cannot be equated with metallic yarn as they are known as distinct and different commercial commodities because in the sale bills issued by the applicant they are described separately, the excise duty on side strips is also levied at the lower rate and that metallic yarn is of even and regular breadth or width while side strips are uneven or rather of irregular breadth or width. Merely because side strips are of uneven width or length, it would be difficult for us to hold that they would not be covered by entry 21. As discussed above, entry 21 is a comprehensive and exhaustive one; it includes all other synthetic fibres and synthetic yarn including their waste. Side strips are a product of the same materials from which synthetic yarn is produced. As discussed above, they are used also for weaving purpose to some extent. Therefore, presuming that side strips are known as side strips and not metallic yarn, it would not make any difference for interpreting comprehensive entry which includes all other yarns not specified elsewhere in other entries. It is admitted that except entry 21 there is no other entry which deals with synthetic fibres and yams. Therefore, presuming that side strips are known as side strips and not metallic yarn, it would not make any difference for interpreting comprehensive entry which includes all other yarns not specified elsewhere in other entries. It is admitted that except entry 21 there is no other entry which deals with synthetic fibres and yams. Hence, considering the facts which are brought on record by the applicant, in our view, it would be apparent that side strips which are produced by the applicant would be covered by the phrase "and all other synthetic fibres and synthetic yarns" of entry 21. In the result, we hold that the Tribunal erred in holding that side strips sold by the applicant were not covered by entry 21 of Schedule II, Part A, to the Gujarat Sales Tax Act, 1969. We, therefore, answer the question in the negative, i.e., in favour of the assessee and against the Revenue. There shall be no order as to costs. Question reframed and answered in the negative.