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Issues: Whether calcined petroleum coke, produced by processing raw petroleum coke, continues to fall within the entry "coal, including coke in all its forms" under section 14(ia) of the Central Sales Tax Act, 1956, and whether the assessee was entitled to reimbursement under section 15(b) of that Act.
Analysis: The entry in section 14(ia) is comprehensive and includes coke in all its forms. The fact that raw petroleum coke undergoes manufacture and emerges as calcined petroleum coke does not take the product outside the declared goods entry. The expression "such goods" in section 15(b) does not require the goods to remain unchanged in physical form where the statutory entry itself covers all forms of coke. The distinction drawn from cases involving entries framed with the phrase "that is to say" was held inapplicable here.
Conclusion: The assessee was not entitled to succeed on the theory that calcined petroleum coke stood outside the declared goods entry; the High Court's view was reversed and the revenue's stand was upheld.
Final Conclusion: Processing of raw petroleum coke into calcined petroleum coke did not exclude the product from the statutory entry covering coke in all its forms, and the appeal failed.
Ratio Decidendi: Where a taxing entry expressly covers a commodity in all its forms, subsequent manufacture that changes its commercial identity does not remove it from the scope of that entry for the purposes of the statutory benefit tied to declared goods.