Tax set-off on processed granules upheld where no new marketable commodity was shown to emerge.

Tax set-off was allowed on low-density polyethylene granules used to manufacture cable-sheathing compound because the Tribunal found the processed material remained low-density polyethylene granules and did not become a new product. The High Court accepted that, as the final fact-finding authority under the Andhra Pradesh General Sales Tax Act, 1957, the Tribunal's conclusion was unsupported by contrary evidence showing emergence of a new marketable commodity known to the commercial world. No basis for interference with that factual finding was made out, so the assessee's claim to set-off was upheld.

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Issues: Whether the assessee was entitled to set-off of tax on the purchase of low-density polyethylene granules used in the manufacture of cable-sheathing compound.

Analysis: The Tribunal recorded a factual finding that the processed granules remained low-density polyethylene granules and did not become a new product. The High Court accepted that the Tribunal, being the final fact-finding authority under the Andhra Pradesh General Sales Tax Act, 1957, had reached a conclusion unsupported by any contrary evidence showing that a new marketable commodity known to the commercial world had come into existence. No basis for interference with that finding was shown.

Conclusion: The assessee was entitled to the set-off claimed, and the finding allowing the claim was not liable to be disturbed.

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