ORDER B. N. Srikrishna J. The issue involved in these appeals is identical and hence they can be decided by a common judgment. We shall take the facts in Civil Appeal No. 6621 of 2000 for deciding the issue. The period involved is 1986-87 to 1993-94; the question is whether cotton based tarpaulin is exigible to sales tax under the Kerala General Sales Tax Act, 1963 ("the KGST Act"). Section 5 of the KGST Act is the charging section which provides for the incidence and levy of sales tax. Under section 5(1)(i) in the case of goods specified in the First or Second Schedule to the KGST Act, tax is leviable at the rates and only at the points specified against such goods in the said Schedules. In the case of goods not specified in the First or Second or Fourth or Fifth Schedule, tax at a specified rate is leviable at all points of sales. Section 9 of the KGST Act provides that a dealer who deals in the goods specified in the Third Schedule shall not be liable to pay any tax under the KGST Act in respect of the sale or purchase of such goods. Section 10 is an enabling power of the State Government to grant exemption from tax, with which we are not concerned presently. Prior to March 31, 1984, there was no specific entry for "tarpaulin" in Schedules I and II. "Tarpaulin" was classified as a separate item under entry 100-C of the First Schedule and made taxable at a specified rate at the point of first sale in the State with effect from April 1, 1984. This position continued till June 30, 1987 when the relevant entry, reading identically, was renumbered as 152, reading as : "P.V.C. cloth, water-proof cloth, rexine and their products and tarpaulin." The rate of tax at the material time was eight per cent at the point of first sale. This situation continued till July 31, 1991. By the Kerala Finance Act, 1991, the commodity "P.V.C. cloth" was deleted from the First Schedule with effect from August 1, 1991 from the relevant entry. This situation continued till March 31, 1992. Under the Kerala Finance Act, 1992 a new entry 106 read as "Rain coat, tarpaulin and products, of water-proof cloth, rexine and PVC cloth" was added. By the Kerala Finance Act, 1991, the commodity "P.V.C. cloth" was deleted from the First Schedule with effect from August 1, 1991 from the relevant entry. This situation continued till March 31, 1992. Under the Kerala Finance Act, 1992 a new entry 106 read as "Rain coat, tarpaulin and products, of water-proof cloth, rexine and PVC cloth" was added. The rate of tax was also increased to 10 per cent without any change in the point of levy. According to the Revenue, "tarpaulin" falls under entry 100-C or 152, as the case may be, and is taxable at 8 per cent at the first point of sale from April 1, 1984 to March 31, 1992 and from April 1, 1992 it falls under entry 106 taxable at 10 per cent at the point of first sale in the State. The Third Schedule to the KGST Act contained entry 7, which read : "Cotton fabrics, woollen fabrics (sic) and rayon or artificial silk fabrics as defined in item Nos. 19, 21 and 22, respectively of the First Schedule to the Central Excises and Salt Act, 1944". At this juncture it may be pointed out that although the First Schedule to the Central Excises and Salt Act, 1944 was repealed in 1986, when the Central Excise Tariff Act, 1985 was brought into force, and the relevant entry for "cotton fabrics" was now to be found in entry 52.06 of the First Schedule to the Central Excise Tariff Act, 1985; entry 7 of the Third Schedule to the KGST Act continued till it was amended in 1992. On April 1, 1992, entry 7 was recast and renumbered as entry 11. The recast entry 11 grants exemption to different goods falling under the Central Excise Tariff Act, 1985, including "cotton fabrics" and contains an exclusion clause which is of relevance to us and reads "Excluding PVC cloth, rexine and waterproof cloth on which duty is not levied under the Additional Duties of Excise (Goods of Special Importance) Act, 1957 (Central Act 58 of 1957)." In 1957, the Parliament brought into force the Additional Duties of Excise (Goods of Special Importance) Act, 1957 ("the ADEA"). Under this Act, certain additional duties were levied on goods which were considered of special importance all over the country. Under this Act, certain additional duties were levied on goods which were considered of special importance all over the country. The background against which this enactment was brought on to the statute book has been considered and explained by this court in the judgment in Godfrey Phillips India Ltd. v. State of U.P. [2005] 2 SCC 515 ([2005] 139 STC 537), vide paragraph 63. Shorn of details, the reason for bringing this Act on the statute book was to discourage different States levying sales tax at different points at different rates on goods considered to be of special importance and simultaneously to ensure that the States did not lose revenue, by charging an additional excise duty under the ADEA, which would be shared with the States. Consistent with this basic philosophy, the Act specified under First Schedule the taxability of the commodities and provided under Second Schedule that the States which levy sales tax on the commodities would not be entitled to share in the additional duties collected for those commodities. Entry 52.06 of the First Schedule read "Cotton fabrics (excluding fabrics covered under heading Nos. 52.09, 52.10 and 52.11), - ....(b) subjected to the process of bleaching, mercerising, dyeing, printing, water-proofing, organdie processing or any other process or any two or more of these processes with the aid of power or steam." The case of the appellant-assessee is that tarpaulin may be manufactured either from cotton cloth or by other methods. As far as cotton based tarpaulin is concerned, the assessee claimed that it was exempted from payment of tax as it fell within the term "cotton fabrics" under entry 7 of the Third Schedule till March 31, 1992 and, thereafter, under entry 11 of the Third Schedule to the KGST Act. Consequently, it was exempted from sales tax under section 9 of the KGST Act during the periods in question. The appellant further contended that under the ADEA, the additional duty levied on any goods is to be shared with those States that do not levy sales tax on the said goods. Admittedly, the First Schedule specifically provides for levy of additional duty on "cotton fabrics". Thus, cotton based tarpaulin which is exigible to additional duty under the ADEA, would be exempt from sales tax under the KGST Act. Moreover, the exclusion clause to entry 11, according to the appellant, fortifies this view. Admittedly, the First Schedule specifically provides for levy of additional duty on "cotton fabrics". Thus, cotton based tarpaulin which is exigible to additional duty under the ADEA, would be exempt from sales tax under the KGST Act. Moreover, the exclusion clause to entry 11, according to the appellant, fortifies this view. By way of an alternative argument, the appellant contended that, "cotton fabrics" being goods declared to be of special importance in inter-State trade or commerce vide section 14 of the Central Sales Tax Act, 1956, sales tax levied on cotton based tarpaulin cannot, in any event, exceed four per cent, as stipulated in section 15 of the Central Sales Tax Act, 1956. On the other hand, it was urged by the Revenue before the High Court and before us that as far as cotton based tarpaulin is concerned, in relation to the KGST Act, "tarpaulin" being the more specific entry as opposed to "cotton fabrics" which is the more general entry; it must be held to fall under the former in the First Schedule and hence be held to be exigible to sales tax under the KGST Act. Further, the Revenue contended that in view of the fact that "tarpaulin" was specifically included in entry 100C with effect from April 1, 1984, entry 152 with effect from July 1, 1987 and entry 106 with effect from April 1, 1992 in the First Schedule to the KGST Act, consequently, it never enjoyed exemption from exigibility to sales tax under the KGST Act from April 1, 1984. The contention is that during the relevant periods, First Schedule to the KGST Act was amended so as to make "tarpaulin" exigible to sales tax. In view of the specific inclusion of "tarpaulin" in the First Schedule, it is contended that the intention manifested by the Legislature was to exclude it from the purview of the general expression "cotton fabrics" in the Third Schedule to the KGST Act. Hence, the Revenue contends that the exemption, if any, from taxability under the KGST Act was lost as a result of inclusion of "tarpaulin" in the entry in the First Schedule from April 1, 1984. Learned Senior Counsel for the Revenue, also attempted to argue that there was a distinction between cotton based tarpaulin and the goods specified in tariff entry 52.06 of the Central Excise Tariff Act, 1985. Learned Senior Counsel for the Revenue, also attempted to argue that there was a distinction between cotton based tarpaulin and the goods specified in tariff entry 52.06 of the Central Excise Tariff Act, 1985. We are unable to countenance this argument for the simple reason that the Tribunal had specifically gone into it and after referring to a number of judgments, it was held that cotton based fabrics have always been included in the term "cotton fabrics" falling under entry 52.06 of the Central Excise Tariff Act, 1985. Thus, undoubtedly cotton based tarpaulin was always covered by the term "cotton fabrics"; which was initially specified as entry 19 of the First Schedule to the Central Excises and Salt Act, 1944 (renamed to "The Central Excise Act 1944 in 1996"); and after the coming into force of the Central Excise Tariff Act, 1985 and the simultaneous repeal of the First Schedule to the Central Excises and Salt Act, 1944, as entry 52.06 in the Central Excise Tarrif Act. The High Court seems to have brushed aside the argument of the appellant by merely focusing on the general principle that when there are two taxing entries - one general and the other specific - then the specific entry would have to be given priority as compared to the general entry. In our view, this principle has no application in the facts of the present appeal as it was not a case of goods being exigible to tax under two entries. On the other hand, the appellant's case is one where the goods had been granted a special exemption provided they were already subjected to tax under the ADEA. The High Court fell into the error of assuming that the problem presented to it with regard to exemption could be solved by resort to the general principle of specific entry versus general entry of a taxable head. The Revenue's contention that when an exemption had already been granted to the concerned goods, if the State Legislature had specifically amended First Schedule so as to include the said goods in First Schedule and make it exigible to tax, it would be incorrect to interpret an entry in a manner as to defeat the object of the statute; is also not tenable. In the first place, there could be nothing like exemption from tax unless goods are exigible to tax. In the first place, there could be nothing like exemption from tax unless goods are exigible to tax. Thus, unless the goods were specified in Schedule I or II of the KGST Act, the goods would not be liable to tax at all and, therefore, there would be no question of granting exemption from tax. Thus, it would be unnecessary to specify them in the Third Schedule, unless by reason of section 5 read with Schedule I or II, the goods were exigible to tax. The fact that "tarpaulin" was included in the First Schedule does not carry the matter any further in favour of the Revenue as it is clear that the exemption operating in favour of cotton based tarpaulin as covered by "cotton fabrics" in the Third Schedule continues as no corresponding change has been made therein by the Legislature even after the amendment of the First Schedule by the introduction of "tarpaulin". The legal result, consequently, is that cotton based tarpaulin would continue to be leviable to tax under the ADEA, and by reason of entry 7/entry 11 of the Third Schedule the said goods would be exempted from exigibility to sales tax under the KGST Act. This legal result would follow irrespective of whatever might have been the presumed intention of the Legislature in amending the First Schedule. The intention of the Legislature has to be gathered from the words used in the statute, and as long as entry 11 in the Third Schedule remains unamended, the legal result of exemption of cotton based tarpaulin from exigibility to sales tax to the KGST Act cannot be avoided. Further, admittedly, under the ADEA, additional duty is leviable on cotton based tarpaulin under the First Schedule to the aforesaid Act. Having regard to the objective behind enacting the ADEA, it is apparent that cotton based tarpaulin on which additional duty is levied under the ADEA was and continues to be exempt from sales tax. At this stage, it would be pertinent to refer to the exclusion clause in entry 11 in the Third Schedule to the KGST Act. The exclusion clause means that where duty has not been levied under the ADEA such goods would be excluded from the purview of entry 11; to put it simply, the goods would lose their exemption under the KGST Act. The exclusion clause means that where duty has not been levied under the ADEA such goods would be excluded from the purview of entry 11; to put it simply, the goods would lose their exemption under the KGST Act. For this reason also, we hold that cotton based tarpaulin is exempted from sales tax under the KGST Act. In the circumstances, we are of the view that the High Court was wrong in denying exemption from sales tax under the KGST Act to the cotton based tarpaulin manufactured by the appellant. The appellant is, therefore, entitled to succeed. The appeal is allowed and the impugned judgments of the High Court and the Tribunal holding that cotton based tarpaulin is exigible to sales tax under the KGST Act are set aside. In view of our aforesaid finding, we find it unnecessary to consider the alternative submission of the appellants in relation to the Central Sales Tax Act, 1956. No other question arises for our decision in this appeal. The appeal is accordingly allowed. No order as to costs. Civil Appeal Nos. 6622-6631 of 2000 and 6632-6634 of 2000. The issue involved being common with Civil Appeal No. 6621 of 2000, these civil appeals are also liable to succeed. These appeals are allowed and the impugned orders are set aside and it is held that cotton based tarpaulin manufactured by the appellants in each of these appeals is entitled to exemption from sales tax under the KGST Act. No order as to costs.