Summarize the following court judgment. vil Appeal Nos. 2665 72 (NT) of 1981 etc. From the Judgment and Order dated 9.1.1980 of the Madras High Court in Tax Case Nos. 894	 895 of 1977	 591	 942	968	 975 of 1979 and W.P. Nos. 4951 and 4952 of 1978. section Padmanabhan	 R. Mohan and R.A. Perumal for the Appel lant. T.A. Ramachandran	 A.K. Sen	 Mrs. J. Ramachandran	 Inbarajan	 P.N. Ramalingam	 A.T.M. Sampath and A.V.V. Nair for the Respondents. The Judgment of the Court was delivered by RANGANATHAN	 J. All these civil appeals and special leave petitions raise a common question as to the interpre tation of an expression used in the . Some of these matters arise out of judgments of the High Court in Tax Revision cases and some out of judgments in writ petitions but the point involved is the same. 1n view of the pendency of the appeals	 we grant leave in the spe cial leave petitions after condoning the delay in filing some of them and proceed to dispose of all the appeals by a common order. The respondents are all dealers in hides and skins carrying on business in the State of Tamil Nadu. As is well known	 raw hides and skins undergo various processes such as cutting	 tanning	 dyeing	 dressing and finishing before they get converted into finished leather and assume a condition fit for the manufacture of various kinds of leather arti cles. The dispute in these appeals is in regard to two items of goods that are sold by these assessees viz. leather splits and coloured leather. The splits are the cut pieces	 often small and irregular	 obtained in the process of cut ting raw of tanned hides and skins either with a view to reduce their thickness or with a view to give them a regular shape. Coloured leather is obtained when the tanned hides and skins are dyed with various colours. The assessee	 inter alia	 deal in these two items	 their manner of such dealing varying from case to case. Some of them obtain the leather splits in the process of cutting and sell them while 449 some purchase the cuttings and sell them as such. So also	 the coloured leather is obtained by some of the assessees in the process of finishing and they sell them while others purchase the coloured leather and sell them as such. The assessees ' claim is that these two items fall in the list of "goods of special importance in inter State trade and com merce" set out in section 14 of the (the 'CST Act ') and that	 therefore	 the assessee is enti tled	 in respect of their sales	 to the concessions avail able under section 15 of the CST Act viz. the benefits of single point taxation and of a smaller rate of tax. The sole ques tion in these appeals is whether the High Court was right in upholding this claim. The principal judgment of the High Court on this point has been reported as Mahi Traders vs State of Tamil Nadu	 [1980] 45 S.T.C. 327. The relevant entry in section 14 of the CST Act reads: "14(1)(iii) hides and skins	 whether in a raw or dressed state. " The short case of the department is: (a) that leather splits or cuttings are "scrap" and do not qualify any longer to be described as hides and skins; and (b) that coloured leather is a totally new and sophisticated product known as leather and can no longer be described merely as hides and skins. The department 's case is best explained in a passage from the order of the Board of Revenue which accepted the depart ment 's contention. It observed: "The contentions have been examined with reference to the connected records. The splits are only pieces of leather obtained in the process of getting leather of uniform thick ness from dressed skins. Such splits cannot be treated as dressed hides and declared goods. The expression "raw or dressed skin" in sec tion 14 of the has a distinct connotation and it cannot be extended to leather bits obtained in a process. These splits are of much lesser value and cannot be equated to dressed skins. In 27 S.T.C. page 385 the Orissa High Court has held that if steel plates are cut to sizes	 they cease to be the original product. What should be con sidered is whether those leather splits are commercially understood as dressed hides and skins. If they are understood only as just skins as claimed	 there is no need to call them as splits in commercial parlance. The Courts have repeatedly ruled that the entries in the Act 450 should be treated only as understood by the Trade. These splits were produced before the Board at the time of hearing. They were found to be thin pieces which can be utilised only for miscellaneous purposes. The contention that these leather splits continue to be dressed skins and are declared goods of inter state importance	 is untenable. The assessing officer was therefore right in treating these splits as scraps and taxing them at the multi point rate	 and in the absence of 'C ' forms	 at 10%. As regards the coloured skins	 once the dressed skins bought are split and the upper layer of uniform size is coloured or dyed	 such coloured skins become different products. They are finished leather sold as coloured skins and not as dressed skins. They are commercially different	 and are treated and dealt with in trade circles as different products. The process of dyeing or colouring changes the commercial nature of the dressed skins. There are different patterns of dyeing and colouring. The complete piece may be dyed or coloured uniformly with a single colour or with a pattern of colours	 depending upon the requirements of the prospective consumers in the market. As the dressed skins are subjected to process	 first by splitting and secondly by colouring they become different products. Pieces of coloured and dyed leather were produced before the Board at the time of hearing. Some pieces were coloured With a single colour on one side and dyed on the reverse. They can be used straightaway for manufacturing leather goods. They were also in patterns. The contention that no change is involved has therefore no force. Both the Appellate Assistant Commissioner and the Assessing Officer were not therefore correct in allowing exemption. " On the other hand	 on behalf of the assessees	 refer ence is made to certain circulars of the authorities which contain a contemporaneous exposition of the meaning of the entry in question	 reliance is placed on the decision of the Sales Tax Appellate Tribunal to the contrary and it is emphasised that	 to say that the one item is called scraps and the other is called leather is not sufficient to take them out of the description "hides and skins	 in a raw or dressed state". It is submitted that cuttings of hides and skins do not cease to be hides and skins merely because they are small pieces and can be loosely described as "scraps". So far as coloured leather is concerned	 according 451 to the assessee	 the question is not whether the coloured skin is described as leather or whether it is a new product different from hides and skins	 as understood generally	 but what exactly is the scope of the expression used in entry (iii) of section 14(1). The submission is that hides and skins are generally described as leather even as soon as tanning is done but the entry in the statute goes much beyond this stage. It takes in all categories of hides and skins right from their raw condition	 through various stages of their tanning and other processing	 right upto the stage when they receive the final finishing touches. We have heard learned counsel on both sides at length and come to the conclusion that the assessees are entitled to the benefit of Ss. 14 and 15 of the CST Act in respect of the two items in question. As far as the first item is concerned	 it is common ground that leather splits are nothing but cut pieces of hides and skins. We fail to see how they cease to be hides and skins. It is no doubt true that they are cheaper and have a separate name but the name only indicates that they are cut pieces. It is not because they have ceased to be hides and skins and constitute a different commercial commodity that they are called 'scraps '. Some of the dealers purchase and sell such splits and such turnover is considerable. There is no material to suggest that they are useless or worthless articles. A loose description of them as 'scrap ' cannot deprive them of the benefit of section 14 of the Act. Turning to coloured leather	 we may	 at the outset	 refer to a very important circumstances referred to by the respondents. When the CST Act came into force on 1.4.1957	 a question was raised regarding the meaning of the expression 'hides and skins in dressed state ' used in section 14. The matter was referred to the leather development wing of the Ministry of Commerce and Industry which gave the following opinion: "Hides and Skins are obtained from either slaughtered or dead animals. The raw hides and skins thus obtained are known to be in the Green State. These are easily putrescible; if proper precautions are not taken they would easily rot and decay. Since tanneries are not always located very near the source of raw hides and skins	 the question of preserving them for a temporary period till they reach a tanning centre assumes importance. Raw hides and skins are 'cured ' by either wet salting	 dry salting or drying. In the 'cured state ' the raw materials can be preserved for a temporary period. In the third state of tempo rary preserva 452 tion	 the hides and skins are 'picked '. During the next stage they are tanned in which state they can be preserved almost indefinitely. These tanned hides and skins are processed further to yield Dressed Hides and Skins which are ready for use. 'Dressed ' or finished material could also be preserved almost indef initely. From the above	 it will be seen that the expression 'Hides and Skins in the raw or dressed State ' refers at one end to the raw material obtained from the slaughtered or dead animals and at the other end to the tanned and finished material; the expression	 therefore	 seems to include the other intermediate stages indicated in the previous paragraphs. Dress ing	 according to the authoritative interpre tations	 would mean the conversion of tanned hides and skins by further suitable processing into leathers of different types which are ready for use" (vide SBT/ . 18(495/14) of November 11	 1957). It would seem though this is not quite clear from the record	 that this opinion held the field for quite some time until the assessments presently in question were made. Even here	 as pointed out by the High Court	 the departmental view was not quite consistent. The Deputy Commercial Tax Officer	 in some of the cases	 was willing to concede that coloured leather	 notwithstanding the colouring	 continued to be dressed hides and skins but thought that leather splits should be brought to multipoint tax. The Assistant Commissioner	 on the contrary	 took the view that splits would continue to be hides and skins. It was the Board of Revenue that decided that both items would fall outside the purview of item (iii) in section 14(1). It has been pointed out by this court in Desh Bandhu Gupta and Ors. vs Delhi Stock Exchange	 ; 	 and Varghese vs ITO	 that a contemporane ous exposition by the administrative authorities is a very useful and relevant guide to the interpretation of the expressions ' used in a statute. Considering that the above clarification was sought for at the earliest point of time when a doubt arose as to the scope of the expression used by the statute and given after considering the technicalities of the processes employed in the manufacture of finished leather by the department fully conversant with this branch of trade and in the context of the provisions of this very statute	 the terms of the statute can well be construed by reference to such exposition	 in the absence of anything in the statute 453 to indicate the contrary. Indeed	 "such interpretation should be shown to be clearly wrong before it is overturned. " Can it then be said that the view expressed above is clearly wrong? We think not; on the contrary	 it is seen to be quite correct. The statutory expression refers to "hides and skins in a dressed state". The guidelines issued for identification of 'finished ' leather for exports by the Indian Standards Institution (ISI) refer to as many as 19 operations or processes undergone during manufacture of 'finished leather ' but 'dressing ' is not one of them. A glossary of terms relating to hides	 skins and leather published by the I.S.I. in 1960 contains the following definitions: CRUSTS: (Crust Leather) Tanned hides and skins without any finish. CURRYING: A series of dressing and finishing processes applied to leather after tanning in the course of which appropriate amounts of oils and greases are incorporated in the leather to give it increased tensile strength	 flexibility and resisting properties. DRESSED RIDES: Tanned hides	 curried or other wise finished	 for various purposes	 such as belting	 harness and saddlery	 travel goods and for upholstery. DRESSING LEATHER: Vegetable tanned hides which may be dressed to suit the purpose for which they are to be used	 such as for harness	 saddlery and other mechanical purposes. LEATHER: The skin or hide of animals prepared by tanning	 which still retains its original fibrous structure more or less intact	 but from which hair or wool may or may not have been removed and which has been treated so as to be imputrescible even after treatment with water. The earlier glossary of such terms published by the British Standards Institution defines 'dressing ' as a "general term for the series of processes employed to con vert certain rough tanned hides and skins and/or crust leather into leather ready for use. " Also	 "Leather" is defined as "a general term for hide or skin which still retains its original fibrous structure more or less intact	 and which has 454 been treated so as to be imputrescible even after treatment with water. " The hair or wool may or may not have been removed. Certain skins	 similarly treated or dressed	 and without the hair removed	 are termed 'fur '. The Dictionary of Leather Terminology published by the Tanners ' Council of America	 describes leather as "the hide and skin of any animal or any portion of such skin	 when tanned	 tawed or otherwise dressed for use. " The above definitions show that hides and skins acquire the name of 'leather '	 even if the hair or wool has not been removed therefrom	 as soon as they receive some treatment which prevents them from putrefaction after treatment with water. Dressing is a stage much later than tanning. Indeed	 from the definitions quoted above	 it will be seen that it is practically the same as giving finishing touches to the leather and making it suitable for the manufacture of par ticular types of goods. Sri Sen invited our attention	 apart from the contempo raneous exposition by the Department	 to the findings of the Tribunal in this regard in an earlier case which had not been appealed against by the Department. The Tribunal had said: "We have carefully considered the records as well as the arguments. We have seen the speci mens of the articles sold. Bits of the same are also on record. We have carefully scruti nised the same. We are unable to say that what the appellants had sold is not leather or in other words dressed hides and skins. The fact that the appellant has done some more finish ing would not take away the resultant product from the classification. We do find that the clarification issued by the Board of Revenue	 Madras and the Govt. of India supports the appellants case. The expert opinion which only says that the resultant product has undergone some chemical changes observed as under: It is	 surely a different product	 because it is a finished leather. It however	 retains the leathery properties of the dressed leather. Hence the expert opinion also fully supports the appellants case inasmuch as it concedes that the resultant product is 'finished leath er '. It is because the issue in appellant 's case is not whether the appellant was selling a different product 455 from the one it purchased	 but whether the appellant was selling tanned leather. In this case	 we do not find any factual basis even to cast any doubt upon the appellant 's claim. It is a pity that the assessing authority should have followed the audit objections without the application of his own mind. Leather from the stage of raw skins to the stage of dressed hides and skins may undergo various stages of changes. Under the classification for the purposes of section 14 of the 	 the various stages are irrelevant. For the purposes of Tamil Nadu General Sales Tax Act	 1959	 only two stages that are rele vant are the skins at the raw stage and the skins in the form of dressed hides and skins (or tanned hides and skins). The appellant purchases semifinished leather and undertakes further process of finishing with a view to colour the hides and skins for certain uses of skins. He says that he purchased the same tanned hides and skins and sold the tanned hides and skins. According to him the products purchased and sold are not different even under the classification by way of the dichot omy between raw and dressed hides and skins under the Tamil Nadu General Sales Tax Act. Under the 	 the appellant is in a much better position	 because all the hides and skins are brought together in one entry. Whether raw or dressed	 the product falls under the same entry. " We are of opinion that this represents the correct view of the scope of the entry in question. The same conclusion is further borne but by the litera ture referred to before us by Sri Ramachandran. 7 of the Encyclopedia Brittanica	 under the word "dress"	 ex plains that the verb has various applications which can be deduced from its original meaning and that "it is thus used not only of the putting on of the clothing but of the pre paring and finishing of leather . . "Vol. 17	 under the head "leather" details the various processes applied in the treatment of hides and skins at all stages	 pre tanning	 tanning and post tanning. Dyeing or colouring is a process which follows tanning but precedes "finishing" (i.e. dress ing) in order to make it suitable for the purpose for which it is required in commercial usage. of the "Wealth of India"	 a publication of the Council of Scientific and Industrial Research (1966)	 dealing with leather under "Industrial Products" explains that "hides and skins are liable to putrefaction and loss unless 456 suitably treated and converted into leather. " Structurally	 hides and skins have a thick middle layer called corium	 which is converted to leather by tanning. The operations involved in leather manufacture however fall into three groups. Pre tanning operations include soaking	 liming	 deliming	 bating and pickling	 and post tanning operations are splitting and shaving	 neutralising	 bleaching	 dyeing	 fat liquoring and stuffing	 setting out	 samming	 drying	 staking and finishing. These operations bring about chemical changes in the leather substance and influence the physical characteristics of the leather	 and different varieties of commercial leather are obtained by suitably adjusting the manufacturing operations. These processes need not be gone into in detail but the passages relied upon clearly show that hides and skins are termed 'leather ' even as soon as the process of tanning is over and the danger of their putrefaction is put an end to. The entry in the CST Act	 however	 includes within its scope hides and skins until they are 'dressed '. This	 as we have seen	 represents the stage when they undergo the process of finishing and assume a form in which they can be readily utilised for manufacture of various commercial articles. In this view	 it is hardly material that coloured leather may be a form of leather or may even be said to represent a different commercial commod ity. The statutory entry is comprehensive enough to include the products emerging from hides and skins until the process of dressing or finishing is done. We are	 therefore	 of the view that the High Court was right in holding that 'splits ' and 'coloured leather ' con tinue to be hides and skins eligible for special treatment under the CST Act. All the appeals	 therefore	 fail and are dismissed. We however make no order as to costs. G.N. Appeals dis missed.

The respondents are dealers in hides and skins. They deal among other things in splits and coloured leather. The splits are the cut pieces	 small and irregular	 obtained in the process of cutting raw or tanned hides and skins either with a view to reduce their thickness or to give them a regular shape. Coloured leather is obtained when the tanned hides and skins are dyed with various colours. The claim of the respondents is that these two items fail in the list of "goods of special importance in inter State trade and com merce" set out in section 14 of the and	 therefore	 entitled to the concessions available under section 15 of the Act	 namely the benefits of single point taxation and of a smaller rate of tax. Such claims were allowed by the assessing authority in respect of coloured leather and in respect of splits he disallowed the claims. The Appellate Assistant Commissioner upheld the order of the assessing authority. The Board of Revenue negativated the contention that leather splits continued to be dressed skins under declared goods of inter State importance and held that these splits are to be treated as 'scraps ' or to be taxed at the multiple rates. As regards coloured leather the Board held that these are commercially different products and that the exemption granted was not correct. The tribunal	 in certain cases	 had held that the assessee was entitled to the con cessions claimed in respect of both items. The respondents moved the High Court by way of Writ Peti tions 446 and tax revision cases and the High Court upheld the claim of the respondents	 holding that 'splits ' and 'coloured leather ' continue to be hides and skins eligible for special treatment under the . The present appeals by special leave are against those judgments of the High Court. The contentions of the appellant State were that the leather splits or cuttings are "scrap" and do not qualify any longer to be described merely as hides and skins and that coloured leather is a totally new and sophisticated product known as leather and can no longer be described merely as hides and skins and as such cannot qualify for exemption. On behalf of the respondents	 a reference was made to certain circulars of the authorities which contain a contem poraneous exposition of the meaning of the entry in question and contended that	 to say that one item being called scraps and the other as leather would not be sufficient to take them out of the description "hides and skins	 in a raw or dressed state" and cuttings of hides and skins would not cease to be hides and skins merely because they are small pieces and can be loosely described as "scraps". As for coloured leather	 it was contended that the exact scope of the expression used in entry (iii) of section 14(1) which re ferred to 'hides and skins whether in a raw or dressed state ' would have to be looked into. Dismissing the appeals	 HELD: 1.1. The High Court was right in holding that 'splits ' and 'coloured leather ' continue to be hides and skins eligible for special treatment under the . [456E] 1.2 A contemporaneous exposition by the administrative authorities is a very useful and relevant guide to the interpretation of the expressions used in a statute. Consid ering that the clarification was sought for from the Minis try of Commerce at the earliest point of time when a doubt arose as to the scope of the expression used by the statute and given after considering the technicalities of the proc esses employed in the manufacture of finished leather by the department fully conversant with this branch of trade and in the context of the provisions of this very statute	 the terms of the statute can well be construed by reference to such exposition	 in the absence of anything in the statute to indicate the contrary. Indeed	 such interpretation should be shown to 447 be clearly wrong before it is overturned. The view of the Ministry was that the expression 'hides and skins in the raw or dressed State ' refers at one end to the raw material obtained from the slaughtered or dead animals and at the other end to the tanned and finished material; the expres sion	 therefore	 seems to include the other intermediate stages as well. 'Dressing ' according to the authoritative interpretations	 would mean the conversion of tanned hides and skins by further suitable processing into leathers of different types which are ready for use. [452F H; 452B D] Desh Bandhu Gupta and Ors. vs Delhi Stock Exchange	 ; ; Verghese vs I.T.O.	 	 relied on. Mahi Traders vs State of Tamil Nadu	 [1980] 45 STC 327	 approved. Definitions in this regard show that hides and skins acquire the name of 'leather ' even if the hair or wool has not been removed therefrom	 as soon as they receive some treatment which prevents them from putrefaction after treat ment with water. 'Dressing ' is a stage much later than tanning. Indeed	 from the definitions it is clear that it is practically the same as giving finishing touches to the leather and making it suitable for the manufacture of par ticular types of goods. The findings of the Tribunal in this regard in an earlier case	 which had not been appealed against by the Department	 that under the 	 the appellant is in a much better position	 because all the hides and skins are brought together in one entry	 and whether raw or dressed	 the product falls under the same entry	 seems to be the correct view of the scope of the entry in question. [454B D; 455E] Glossary of terms relating to hides	 skins and leather published by ISI in 1960: Dictionary of Leather Terminology published by the Tanners ' Council of America. Encyclopedia Britannica Vol. 7 and	 'Wealth of India '. 	 a publica tion of the Council of Scientific and Industrial Research	 1966	 relied on. Hides and skins are termed 'leather ' even as soon as the process of tanning is over and the danger of their putrefaction is put an end to. The entry in the 	 however	 includes within its scope hides and skins until they are 'dressed '. This represents the stage when they undergo the process of finishing and assume a form in which they can be readily utilised for manufacture of various commercial articles. In this view	 it is hardly material that coloured leather may be a form of leather or may even be said to represent a different commer 448 cial commodity. The statutory entry is comprehensive enough to include the products emerging from hides and skins until the process of dressing or finishing is done. [456C E]