Declared goods restrictions on watery coconuts made the State sales tax levy invalid to that extent.

Watery coconuts were treated as a distinct stage of coconut commodity, not as tender or dried coconuts, but still within the declared goods covered by section 14 of the Central Sales Tax Act, 1956. Because goods falling within section 14 remain subject to the restrictions in section 15, the State could impose sales tax only within those limits. The Court found no material to exclude watery coconuts from the declared category of coconut and held the 7% levy under the Rajasthan Sales Tax Act invalid to that extent, striking down the notification accordingly.

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Issues: Whether watery coconuts fall within the declared goods covered by section 14 of the Central Sales Tax Act, 1956, so that the State notification levying sales tax at 7 per cent under section 5 of the Rajasthan Sales Tax Act, 1954 is invalid to that extent.

Analysis: Watery coconuts were treated as neither tender coconuts nor dried coconuts, but as a distinct stage of the same commodity which ultimately becomes copra. The Court noted the statutory scheme that goods falling within section 14 are subject to the restrictions in section 15, and found no material to show that watery coconuts were outside the scope of the declared category of coconut. Since the goods were covered by section 14, the State could tax them only within the limits imposed by section 15.

Conclusion: The levy of sales tax at 7 per cent on watery coconuts was held to be bad in law and the notification was struck down to that extent.

Ratio Decidendi: Goods expressly covered by section 14 of the Central Sales Tax Act, 1956 can be subjected to State sales tax only within the restrictions imposed by section 15 of that Act.

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