SHAW WALLACE & CO. LTD. vs STATE OF TAMIL NADU

The Supreme Court held that under Section 3 of the Tamil Nadu General Sales Tax Act, 1959, fertilizer mixtures prepared by dry-mixing chemical fertilizers do not qualify for tax exemption as they are considered a different commodity from their individual components. The Court emphasized that the mixtures possess distinct chemical properties and uses, thus failing to meet the criteria for exemption outlined in the First Schedule Entry 21. Consequently, the appeal was dismissed, affirming the Tribunal's decision to impose tax on the fertilizer mixtures.