Declared goods taxation requires a fixed taxable stage, and reassessment may follow if single-stage levy limits are not exceeded.

Declared goods could not be validly assessed where the taxing provision did not itself fix the stage of levy and no notification was produced to identify the taxable point. Section 15(a) of the Central Sales Tax Act restricts tax on declared goods to the prescribed rate and to one stage only, so assessments made without a notified stage could not stand. However, quashing the assessments did not extinguish the underlying liability; reassessment remained open to determine whether the goods had already suffered tax at one stage and to ensure that no further tax was levied beyond the statutory limit.

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Issues: Whether the assessment orders on declared goods were invalid for want of a notification specifying the stage of taxation, and whether the quashing of the assessments precluded reassessment if the goods had not already suffered tax at an earlier stage.

Analysis: Section 15(a) of the Central Sales Tax Act, 1956 imposes a restriction that tax on declared goods cannot exceed the prescribed rate and cannot be levied at more than one stage. Section 5(2)(a)(ii) of the Bengal Finance (Sales Tax) Act, 1941, as applied to Delhi, contained no guideline fixing the stage at which tax was to be levied. Although section 5A empowered the authority to specify the taxable point by notification, no such notification was produced. In that situation, the assessment orders could not stand. At the same time, quashing the assessments did not automatically eliminate the underlying liability if the goods had already been taxed at one stage or if reassessment could be made consistently with the statutory restriction.

Conclusion: The assessment orders were liable to be quashed, but reassessment was left open to ascertain whether the goods had already suffered tax at one stage and to ensure that no further tax was levied beyond the statutory limit.

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