JUDGMENT The judgment of the Court was delivered by V. V. KAMAT, J. - These two revision cases cover two assessment years, 1985-86 and 1986-87 respectively. The question is, which of the two entries governing the situation of the concerned assessment years would govern levy of sales tax under the Kerala General Sales Tax Act, 1963. These are entry Nos. 94 and 95 in the First Schedule. It would be much more convenient to reproduce the two entries as follows : "94. Splints and veneers At the point of first sale in the State 4 by a dealer who is liable to tax under section 5. 95. Plywood, veneer do. 10" plywood and hardboard. If entry 94 governs the situation, the levy of tax would be 4 per cent whereas if the situation is governed by entry No. 95, it would be 10 per cent. 2. During the years in question the petitioner-assessee trading in the name and style "Southern Veneers and Wood Works Ltd." showed turnover of Rs. 5,02,140 and Rs. 5,82.500 respectively for the above years. 3. The assessing authority (Agricultural Income-tax and Sales Tax Officer, Thalassery) observed that "veneer" means one which is used for manufacturing match box as against the veneer manufactured by the dealer in this case used as the decorative veneer and manufacturing plywood. Consequently he held that the veneer manufactured by the dealer would be veneer plywood attracting the levy of sales tax as per entry No. 95. Accordingly the assessment was completed by the order dated December 28, 1989. 4. The first appellate authority (the Appellate Assistant Commissioner, Agricultural Income-tax and Sales Tax, Kannur) also proceeded to confirm the said decision. The appellate authority has discussed the question in a limited manner as follows : "I have considered the above contentions carefully. The only dispute in this case is with regard to the rate of tax applicable. It is the case of the officer that the veneer manufactured by the appellant is used as decoration veneer used for in manufacturing plywood and it will not come under entry No. 94 of the First Schedule of the KGST Act, i.e., splints and veneers used for manufacturing match boxes. I am also of opinion that the veneer manufactured by the appellant is veneer plywood taxable at 10 per cent under entry No. 95 of the First Schedule of the KGST Act. I am also of opinion that the veneer manufactured by the appellant is veneer plywood taxable at 10 per cent under entry No. 95 of the First Schedule of the KGST Act. I accordingly dismiss the appeal as one devoid of any merit." 5. The question, when taken up before the Kerala Sales Tax Appellate Tribunal is discussed in paragraph 7 of the order in the following manner : "We have considered the arguments of both sides and verified the file. In all the returns filed, the assessee has shown the goods sold as 'veneers' and the rate of tax is shown as 4 per cent. The relevant entries in the First Schedule to the KGST Act, 1963 is as under : Item No. 94 : Splints and veneers ... 4 per cent. Item No. 95 : Plywood, veneer plywood ... 10 per cent. and hardboard., Item No. 94 is 'splints and veneers'. The veneers mentioned here is clearly those used for manufacture of match boxes. But, item No. 95 is 'plywood, veneer plywood and hardboard'. The assessing authority has assessed the commodity as veneer plywood. The appellant has produced the sample of veneers. 'Veneer' is thin covering of finer wood for furniture, etc. The item is used for manufacture of the decorative plywood. So, it will come under the item veneer plywood in item No. 95 of the First Schedule, taxable at 10 per cent. So, the levy of tax at 10 per cent is proper and therefore upheld." 6. From the above discussion it would be seen that the goods sold are sold as veneers. It would also be seen that item No. 94 considers veneers and splints as independent items as different from those specified in item No. 95. Those specified in item No. 95 as would be seen are essentially plywood, veneer plywood and hardboards. On the face of reading the entries, entry No. 94 refers to veneer simpliciter as against what is conveyed by item No. 95 is plywood and its varieties specified in the category described in a general sense as plywood. The Tribunal has clearly observed that the veneer has its uses and according to the reasoning the commodity "veneer" to be found in item No. 94 would be one that is used for manufacture of match boxes as against the one referred to in entry No. 95 as "veneer plywood". The Tribunal has clearly observed that the veneer has its uses and according to the reasoning the commodity "veneer" to be found in item No. 94 would be one that is used for manufacture of match boxes as against the one referred to in entry No. 95 as "veneer plywood". It is not possible to accept the said reasoning when both the entries are read to find that entry No. 94 refers to veneers simpliciter as against entry No. 95 which refers to plywood and its categories, veneer plywood being one of them in the context finding place in the middle order of the specification of the said entry. On plain reading when "veneer" is required to be considered, its use cannot be contemplated in the context. In fact, the Tribunal has also attempted to understand the meaning of the word "veneer" to mean "a thin covering of finer wood for furniture, etc.". The learned Additional Advocate-General sought aid to understand the term "veneer" from the Webster's Third New International Dictionary, Volume 3 to mean more or less the same thing. It would be more convenient to reproduce item No. (2) therein as follows : "(2) any one of the thin layers that are glued or otherwise bonded together to form plywood." Even after taking into consideration the situation would not change because on a plain reading of entry Nos. 94 and 95 what is relevant is the article which is subject to levy of tax. Reading the above observations of the three authorities, there is no difficulty about the article and it is attempted to be understood in terms of its use which is not permissible. In taxing statute what is taxable is the article referred to in the entry and it cannot be understood in the context of its use which is likely to be a future step on the basis of the same. This particular situation is clarified by the advent of the Finance Act, 1987 (Act No. 18 of 1987) in entry No. 180 of the First Schedule thereof as against entry No. 6 of the Fifth Schedule thereof. These entries are as follows : Entry 180 of First Schedule : ------------------------------------------------------------------------ "Sl. Description of Point of levy Rate of tax No. goods (per cent) ------------------------------------------------------------------------ 180 Splints and veneers At the point of first sale 4." for matches. These entries are as follows : Entry 180 of First Schedule : ------------------------------------------------------------------------ "Sl. Description of Point of levy Rate of tax No. goods (per cent) ------------------------------------------------------------------------ 180 Splints and veneers At the point of first sale 4." for matches. in the State by a dealer who is liable to tax under section 5. ------------------------------------------------------------------------ Entry 6 of Fifth Schedule : ------------------------------------------------------------------------ "Sl. Description First point Rate Second point of No. of goods of levy of tax of levy (per cent) ------------------------------------------------------------------------ 6 Plywood, veneer At the point 10 At the plywood and of first sale point of last hardboards and in the State sale in the veneers not by a dealer State by a covered by entry who is liable dealer who is 180 of the First to tax under liable to tax Schedule. section 5 to under section 5. a registered dealer ------------------------------------------------------------------------ Rate Where there Rate of are no two points of tax of sale in the State tax (per cent) per cent) ------------------------------------------------------------------------ 2 At the 12" point of first sale in the State by a dealer who is liable to tax under section 5 to person other than a registerd dealer. ------------------------------------------------------------------------ It would be at once seen that the Legislature also understood the difficulty creating confusion in the matter and separated splints and veneers for matches as against "veneer plywood" distinctly leaving no confusion to be confounded as a result. There is no dispute that this Finance Act No. 18 of 1987 came into effect from July 1, 1987 and would not have any application to the proceedings before us except and by way of aid to the understanding of the entries Nos. 94 and 95 as they stood at the time for function and interplay. 7. Thus it would be seen that the article sold was veneer and would be governed by entry No. 94 consequently being subject to tax at 4 per cent as the situation governed with reference to the assessment years in question. For the above reasons the two revision cases succeed. 7. Thus it would be seen that the article sold was veneer and would be governed by entry No. 94 consequently being subject to tax at 4 per cent as the situation governed with reference to the assessment years in question. For the above reasons the two revision cases succeed. Consequently all the orders in these two revision cases stand quashed and set aside and the trial authority is directed to proceed with the question of levy of sales tax by application of entry No. 94 governing the situation and pass orders accordingly with regard to the amount of tax to be paid by the assessee on the above basis. Order accordingly. Petitions allowed.