Single-point purchase tax on declared goods attaches at the miller's initial purchase, not on later crushing or resale.

Under the Andhra Pradesh General Sales Tax Act, 1957 read with the Central Sales Tax Act, 1956, purchase tax on declared goods such as groundnut was confined to the miller's initial purchase. Sections 14 and 15 of the Central Sales Tax Act, together with section 6 and item 6 of the Third Schedule, showed a single-point levy: liability arose when the miller purchased the groundnut, and the taxing power was exhausted once that purchase suffered tax. Subsequent crushing, resale, or other dealings did not shift or postpone the taxable event, and no additional word such as "first" had to be read into the entry.

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Issues: Whether, under the Andhra Pradesh General Sales Tax Act, 1957 read with the Central Sales Tax Act, 1956, purchase tax on groundnut was attracted at the point of the miller's first purchase or only on crushing, last purchase, or subsequent dealings.

Analysis: Groundnut being declared goods, the State's power to levy purchase tax was controlled by sections 14 and 15 of the Central Sales Tax Act, 1956 and by section 6 of the Andhra Pradesh General Sales Tax Act, 1957 and item 6 of the Third Schedule. The charging event was the miller's purchase of groundnut, and liability attached when that purchase was made. The scheme permitted levy only at one stage, so once a quantity of groundnut had suffered tax, the taxing power in respect of those goods stood exhausted. Later crushing, resale, or other subsequent dealings did not postpone or shift the taxable event. The court also held that no word such as "first" needed to be read into the entry, because the statutory scheme itself confined levy to the initial taxable purchase.

Conclusion: The purchase tax was payable at the point of purchase by the miller, not on crushing or on last purchase, and the challenge by the assessees failed.

Final Conclusion: The appeals were dismissed, and the levy of purchase tax on the millers' purchase of groundnut was upheld as arising at the first purchase stage under the statutory scheme.

Ratio Decidendi: Where the statute prescribes a single-point levy on declared goods, the taxable event is the initial purchase by the class of dealer identified in the charging schedule, and later dealings in the same goods do not create a fresh liability once the taxing power has been exhausted.

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