ORDER : (Per Hon’ble Sri Justice R. Raghunandan Rao) All these Writ Petitions is being disposed of by way of this Common Order as all the Writ Petitions arising out of the same issues. 2. Heard Sri G. Narendra Chetty, learned counsel for the petitioners and the learned Government Pleader for Commercial Tax. 3. In Writ Petition Nos.36378 of 2012, 14544 of 2019 & 10478 of 2023, the issues that arise before this Court is on the question of clarification of the galvanized iron sheets. The issue that arises in W.P.No.28038 of 2013 is on the question of whether the Deputy Commissioner, could have refused deferment of hearing despite the said question being before this Court in the aforesaid three Writ Petitions. 4. The petitioners are said to be dealing with iron and steel products, including corrugated iron sheets, which are prepared by the petitioners, by taking plain sheets or plain coils and pressing them into corrugated sheets. 5. The petitioners, for the assessment periods concerned, had been assessed by the assessing officers, who had accepted the contentions of the petitioners, that corrugation of iron sheets or coils would not result in a different commodity and the petitioners were entitled to pay tax by treating them as commodities falling within the Entry 70(vi) of the IV Schedule of the Andhra Pradesh Value Added Tax, 2005 [for the short “the AP VAT Act”]. 6. These assessments were subjected to revision where under, the territorial Deputy Commissioner, had revised the said assessment orders and had held that corrugated iron sheets would not fall within the aforesaid entry and should be treated as unclassified goods. The effect was that the petitioners would have to pay tax at the rate of 12.5% or 14% as against of 4% leviable under the Entry 70(vi) of the IV Schedule of the AP VAT Act. 7. Entry 70(vi) of the IV Schedule of the AP VAT Act reads as follows:- “Entry -70:- Iron and steel, that is to say: (i)…. (ii) … (iii) …. (iv) … (v) …. (vi) Sheets, hoops, strips and skelp, both black and galvanized, hot and cold rolled, plain and corrugated in all qualities, in straight lengths and in coil form as rolled and in revitted condition.” 8. (ii) … (iii) …. (iv) … (v) …. (vi) Sheets, hoops, strips and skelp, both black and galvanized, hot and cold rolled, plain and corrugated in all qualities, in straight lengths and in coil form as rolled and in revitted condition.” 8. Sri G. Narendra Chetty, learned counsel appearing for the petitioners, in these cases, would submit that the issue of whether pressing plain sheets or coils into corrugated sheets would result in a different commodity came up before the Calcutta High Court in the case of Phanidra Nath Manna & Company Vs. Commercial Tax Officer & Ors., 33 STC 292 (CAl). He would also rely upon the Judgment of the Hon’ble Supreme Court of India in the case of Gujarat Steel Tubes Ltd Vs. State of Kerala & Ors, 74 STC 176 (SC). Apart from this, Sri G. Narendra Chetty, learned counsel for the petitioner also relied upon the Judgment in the case of State of Tamilnadu Vs. Pyeralal Malhotra, 37 STC 319 (SC). 9. Learned Government Pleader for Commercial Tax would contend, relying upon the observations in the impugned orders of revision, that the petitioners had customized the plain sheet or coils into corrugated sheets and had bent them and had cut them into lengths according to the requirement of the customers, which should result in creation of a new product which would not fall within the ambit of Entry 70(vi) of the IV Schedule of the AP VAT Act. He would contend that the processing of the plain sheets or coils, to meet the needs of the customers, automatically creates a new commercial product which cannot be taken to fall within the ambit of Entry 70(vi) of the IV Schedule of the AP VAT Act. 10. In the case of State of Tamilnadu Vs. Pyeralal Malhotra, 37 STC 319 (SC) the Hon’ble Supreme Court of India was considering Section-14 of the Central Sales Tax Act, 1956 which stipulated that certain goods enumerated to be special importance in inter-state trade or commerce could be taxed only once. One of the entries enumerated therein was iron and steel with various subcategories of iron and steel being set out. Sub-category VI of the said provision is in pari materia with Entry 70(vi) of the IV Schedule of the AP VAT Act. 11. One of the entries enumerated therein was iron and steel with various subcategories of iron and steel being set out. Sub-category VI of the said provision is in pari materia with Entry 70(vi) of the IV Schedule of the AP VAT Act. 11. Under Section 14 (iv) of the CST Act, the various products of Iron & Steel were sub-categorised into (i) to (xvi). The issue before the Hon’ble Supreme Court in the case of State of Tamilnadu Vs. Pyeralal Malhotra was whether a product, which is created or procured from another product within the same sub-category, can be treated commercially as a different product, whose sale is exigible to tax. The Hon’ble Supreme Court replied in the negative. 12. This entry under the Central Sale Tax, Act has now been shifted as the Entry 70(vi) of the IV Schedule of the AP VAT Act. 13. Applying the said principles set out by the Hon’ble Supreme Court of India, it would have to be seen whether corrugating plain sheets or coils would create a product which goes out of the Entry 70(vi) of the IV Schedule of the AP VAT Act. 14. Entry 70(vi) of the IV Schedule of the AP VAT Act includes sheets, hops, strips and skelp, which could be black or galvanished or hot and cold rolled or plain and corrugated. This would mean that corrugating plain sheets resulting in corrugated iron sheets or corrugated coil from iron or steel into sheets would not move any of the products out of the sub-entry. 15. The learned Government Pleader for Commercial Tax would contend that the requirement is that such product should be in straight length or in coil form whereas the corrugated sheets which are bent to meet the requirements of the customers of the petitioners cannot be treated to be straight lengths. 16. The said contention of the learned Government Pleader for Commercial Tax cannot be accepted for the reason that the iron sheets or the steel sheets which are corrugated would remain as straight lengths even if the said sheets are bent. This is because the iron or steel would be either in the form of sheets or in coil form. In such circumstances, the term “straight lengths” would have to be understood to be sheets. 17. This is because the iron or steel would be either in the form of sheets or in coil form. In such circumstances, the term “straight lengths” would have to be understood to be sheets. 17. Apart from this, the view of the Calcutta High Court in the case of Phanidra Nath Manna & Company Vs. Commercial Tax Officer & Ors, 33 STC 292 (CAl) can also be taken into account. The Calcutta High Court while dealing with a similar issue had held as follows: “If flat iron sheets are covered by entry "G.I. sheet", they do not cease to be so by mere alteration of shape by corrugation. The process of corrugation is one of alteration of shape and it does not make galvanised iron sheets a different article or product of iron. While interpreting items in statutes like the Sales Tax Act, resort should be had not to the scientific or technical meanings of such terms, but to their popular meanings or the meanings attached to them by those dealing in them, that is to say, to their commercial sense: Commissioner of Sales Tax, Madhya Pradesh v. Jaswant Singh Charan Singh. In commercial parlance galvanised sheet includes both corrugated and plain sheets. The certification marks scheme formulated by the Indian Standard Institute for steel products shows that galvanised sheet includes corrugated and plain sheets. Such sheets after corrugation do not lose their character as iron sheets.” 18. We are in respectful agreement with this view. For both these reasons, the impugned orders of revision which are detailed below are set aside. Sl.No. Writ Petition Number Impugned Revision order Number 1. 36378 of 2012 Rv.No.38/2011-12/A6.TIN:28438947169/2007-08 to 10-11, dated 12.09.2012. 2. 14544 of 2019 DC: 2599, dated 07.09.2019. 3. 10478 of 2023 DIN3714032366494, dated 14.03.2023 19. As far as the Writ Petition No.28038 of 2013 is concerned, the Writ Petition has been filed being aggrieved by the rejection of the request of the petitioner for deferment till this issue is decided by this Court in these three Writ Petitions. In view of the decision of this Court, any further revision or assessment or re-assessment would have to be in accordance with the law laid down by this Court herein. Accordingly, nothing would further survive in the said Writ Petition. 20. In view of the decision of this Court, any further revision or assessment or re-assessment would have to be in accordance with the law laid down by this Court herein. Accordingly, nothing would further survive in the said Writ Petition. 20. Therefore, the Writ Petition Nos.36378 of 2012, 14544 of 2019 & 10478 of 2023 are allowed, while Writ Petition No.28038 of 2013 is disposed of with the above observations. There shall be no order as to costs. As a sequel, pending miscellaneous petitions, if any, shall stand closed.