Declared goods and processing: dressed hides and skins are distinct commodities and may be taxed separately.

Processing raw hides and skins into dressed hides and skins creates a distinct commercial commodity for purposes of the Central Sales Tax Act, 1956. Sections 14 and 15, read with the declared-goods scheme, do not treat the two forms as the same taxable item merely because they appear in the same statutory entry. As a result, a prior levy on the purchase of raw hides and skins does not bar taxation of inter-State sales of dressed hides and skins, and the State amendment and schedule entry were not inconsistent with the Central Act.

---

---

Issues: (i) Whether raw hides and skins and dressed hides and skins are the same commodity for the purposes of the Central Sales Tax Act, 1956; (ii) Whether the State could levy tax on inter-State sales of dressed hides and skins after tax had already been paid on the purchase of raw hides and skins, and whether the impugned State amendment was ultra vires.

Issue (i): Whether raw hides and skins and dressed hides and skins are the same commodity for the purposes of the Central Sales Tax Act, 1956.

Analysis: The statutory scheme in sections 14 and 15 of the Central Sales Tax Act, 1956 was examined along with earlier authority. The expression in section 14(iii), read with the scheme of declared goods, did not treat raw hides and skins and dressed hides and skins as one and the same commodity. The process of dressing was held to result in a separate commercial commodity, and mere inclusion under the same entry did not make them a single taxable item.

Conclusion: Raw hides and skins and dressed hides and skins are different commercial commodities.

Issue (ii): Whether the State could levy tax on inter-State sales of dressed hides and skins after tax had already been paid on the purchase of raw hides and skins, and whether the impugned State amendment was ultra vires.

Analysis: Since the two forms were held to be distinct commodities, the levy on dressed hides and skins did not amount to taxing the same goods more than once. Section 15 of the Central Sales Tax Act, 1956 did not prohibit the levy because the restriction against multiple taxation applied to the same declared goods, not to distinct commercial goods emerging after processing. On that footing, the State amendment and the corresponding schedule entry were not inconsistent with the Central Act.

Conclusion: The State was competent to levy tax on dressed hides and skins, and the impugned amendment was not ultra vires.

Final Conclusion: The appeals failed because the challenged levy on dressed hides and skins was sustained on the basis that the processed goods were commercially distinct from the raw goods and were separately taxable.

Ratio Decidendi: Where processing results in a distinct commercial commodity, a prior levy on the raw material does not bar taxation of the processed product under the declared-goods scheme, and mere inclusion in the same statutory entry does not make both forms one commodity for tax purposes.

---