Declared goods under sales tax law: separately listed iron and steel items remain distinct taxable commodities after transformation.

The article explains that the listed forms of "iron and steel" in section 14 of the Central Sales Tax Act are separate commercial commodities, not one taxable substance. The use of "that is to say" and the separate enumeration of sub-items means each item retains its own identity for sales tax purposes, so a transformed finished product may be taxed even if its raw material was taxed earlier. It also states that the Tamil Nadu sales tax levy on the declared goods was not shown to violate section 15 of the Central Sales Tax Act or article 286(3) of the Constitution, and was therefore supported by the statutory scheme.

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Issues: (i) Whether the entries in section 14 of the Central Sales Tax Act describing "iron and steel" enumerate distinct commercially separate goods, so that each specified sub-item is separately taxable and not protected from tax merely because its raw material was earlier taxed; (ii) whether the Tamil Nadu sales tax levy on the goods in question was barred by section 15 of the Central Sales Tax Act read with article 286(3) of the Constitution of India.

Issue (i): Whether the entries in section 14 of the Central Sales Tax Act describing "iron and steel" enumerate distinct commercially separate goods, so that each specified sub-item is separately taxable and not protected from tax merely because its raw material was earlier taxed.

Analysis: The statutory description of "iron and steel" was held to be an enumeration of separate categories of commercial goods, not a single taxable substance irrespective of form. The expression "that is to say" and the separate numbering of the listed items showed that each specified item retained its own identity as a commercial commodity for sales tax purposes. Once a commodity of one commercial description was transformed into another commercially distinct commodity, the new article became separately taxable. Earlier taxation of the raw material did not prevent taxation of the finished commodity if it had emerged as a distinct commercial item.

Conclusion: The listed forms of iron and steel are separately taxable commodities, and prior taxation of the raw material does not bar taxation of the transformed goods.

Issue (ii): Whether the Tamil Nadu sales tax levy on the goods in question was barred by section 15 of the Central Sales Tax Act read with article 286(3) of the Constitution of India.

Analysis: Section 15 imposes restrictions on State taxation of declared goods, but no violation of those restrictions was shown. The Tamil Nadu provisions taxing declared goods at the specified point and rate were consistent with the Central Act as interpreted. The State levy therefore stood supported by the statutory scheme governing declared goods.

Conclusion: The Tamil Nadu sales tax levy was not barred by section 15 of the Central Sales Tax Act or article 286(3) of the Constitution of India.

Final Conclusion: The decision restored the assessment authorities' orders in the revision matters and left the revenue authorities free to proceed with the surviving factual and legal questions in the writ matters, resulting in relief to the Revenue.

Ratio Decidendi: Where a sales tax statute separately enumerates commodities under a general heading, each enumerated item is treated as a distinct commercial taxable unit, and taxation may attach to the transformed commodity even if its raw material had been taxed earlier.

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