Summarize the following court judgment. Civil Appeal No. 814 of 1964. Appeal by special leave from the judgment and order dated October 24	 1961 of the Madhya Pradesh High Court in Misc. Petition No. 125 of 1958. I.N. Shroff	 for the appellants. C.B. Agarwala and C. P. Lal	 for the respondent. The Judgment of the Court was delivered by Subba Rao	 J. This appeal by special leave raises the question of the intepretation of Item No. 39 of the Notification 753 No. 58	 dated October 24	 1953	 hereinafter called the 'Notification '	 issued by the Government of Madhya Bharat under the Madhya Bharat Sales Tax Act	 Samvat 2007 (Act No. 30 of 1950)	 hereinafter called the Act. The facts are as follows : Hiralal	 the respondent	 is the: manager of a joint Hindu family carrying on business in the name and style of "Messrs. Tilokchand Kalyanmal". The joint family owns a re rolling mill situated in Indore City called the Central India Iron and Steel Company. The said family purchases scrapiron locally and imports iron plates from outside and after converting them into bars	 flats and plates in the Mills sells them in the market. The respondent made a default in furnishing the returns prescribed by section 7(i) of the Act for the period April 1	 1954	 to March 31	 1955. On February 27	 1956	 the Sales tax. Officer	 Indore	 determined the taxable turnover at Rs. 2	26	000and the sales tax payable thereon at Rs. 8	000; and he also imposed a penalty of Rs. 1	000 under section 14 (1) (c) of the Act. On the same day he issued demand notices to the respondent for the payment of the said sales tax and the penalty. On September 10	 1956	 the respondent filed a petition in the High Court of Madhya Bharat (afterwards Madhya Pradesh) under articles 226 and 227 of the Constitution for the issue of appropriate writs quashing	 the assessment of tax and penalty and to restrain the State from giving effect to the said orders of the Sales tax Officer. A Divi sion Bench of the High Court held that the iron bars	 flats and ' plates sold by the respondent were exempted from sales tax under the Notification. In that view	 the orders of the Sales tax Officer were quashed. The state has filed the present appeal	 by special ' leave. The only question in this appeal is whether the said iron bars	 flats and plates are not iron and steel within the meaning of ' Item No. 39 of the Notification. Parliament enacted Essential Goods (Declaration and Regulation of Tax on Sales or Purchases) Act	 1952 (Act No. 52 of ' 1952)	 which came into force on August 9	 1952. In Schedule I of the said Act	 iron and steel were declared essential for the life of the community. Thereafter	 the Government of Madhya. Bharat	 in exercise of the powers conferred by section 5 of the Act	 issued the Notification as also Notification No. 59	 dated October 24	 1953. The material part of Schedule I of Notification 58 reads 754 "No tax shall be payable on the sale of the following goods S.No. Description of goods. 39 Iron and steel. Notification No. 59 described the goods sales of which were taxable at particular rates. Schedule IV thereof reads : "List of articles under section 5 of the Madhya Bharat Sales Tax Act	 1950	 on the assessable sale proceeds of which sales tax at the rate of Rs. 3/2/ per cent. shall be payable	 showing the nature of articles on which the tax is payable. Name of article Stage of sale in Madhya Bharat at which the tax is payable. 9 . goods prepared from any Sale by imported or pro metal sale by importer or producer. ducer. other than gold and silver. . Learned counsel for the State contends that the expression "iron and steel" means iron and steel in the original condition : and not iron and steel in the shape of bars	 flats and plates. In our view	 this contention is not sound. A comparison of the said two Notifications brings out the distinction between rawmaterials of iron and steel and the goods prepared from iron and steel : while the former is exempted from tax	 the latter is taxed. 'Therefore	 iron and steel used as raw material for manufacturing other goods are exempted from taxation. So long as iron and steel continue to be raw materials	 they enjoy the exemption. Scrap iron purchased by the respondent was merely re rolled into bars	flats and plates. They were processed for convenience of sale. The raw materials were only re rolled to give them attractive and acceptable forms. They did not in the process lose their character as iron and steel. The dealer sold "iron and steel" in the shape of bars	 flats and plates and the customer purchased "iron and steel" in that shape. We	 therefore	 hold that the bars	 flats and plates sold by the assessee are iron and steel exempted under the Notification. The conclusion arrived at by the High Court is 	correct. In the result	 the appeal fails and is dismissed with costs. Appeal dismissed.

The respondent as head of a joint Hindu family owned a re rolling mill at which scrap iron locally purchased	 and iron plate 	 imported from outside	 were converted into bars	 flats and plates in the Mills and thereafter sold in the market. The sales tax authorities held that iron bars	 flats and plates sold by the respondent were not 'iron and steel ' exempted by notification No. 58 dated October 1953 issued under the Essential Goods (Declaration and Regulation of Sales and Purchasees) Act	 1952. In a petition under articles 226 and 227 filed by the respondent challenging the said assessment the High Court decided that iron bars	 flats and plates were exempted under the notification. The State appealed to this Court. HELD : Goods prepared from metals other than gold and silver are made taxable by notification No. 59 whereas notification No. 58 exempts iron and steel from tax. A comparison of the said two notifications brings out the distinction between raw materials of iron and steel and the goods prepared from iron and steel. While the former is exempted from tax the latter is taxed. Therefore iron and steel used as rawmaterial for manufacturing other goods are exempted from taxation. So long as iron and steel continue to be raw materials	 they enjoy the exemption. Scrap iron purchased by the respondent was merely rerolled into bars	 flats and plates for convenience of sale. The rawmaterials were only re rolled to give them attractive and acceptable forms. They did not in the process lose their character as iron and steel. The bars	 flats and plates sold by the respondent were therefore iron and steel exempt under the notification. [754 D G]