Single-point levy on declared goods cannot turn on year-end unsold stock when identifying the last purchase in the State.

Declared goods subject to single-point levy under section 14 and section 15(a) of the Central Sales Tax Act must be assessed by reference to the full chain of successive transactions, not by confining the enquiry to the assessment year alone. The phrase "last purchase in the State" cannot be restricted so as to tax unsold stock merely because it remained at year-end, since the relevant levy stage is the final purchase before export outside the State or use in manufacture. The contrary year-bound approach would permit multiple taxation and defeat the single-point levy scheme. On that basis, assessment based only on year-end unsold stock was improper.

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Issues: Whether, for declared goods liable to single point levy, the expression "last purchase in the State" is to be confined to transactions occurring within the assessment year so as to tax unsold stock remaining at the year-end.

Analysis: Declared goods under section 14 of the Central Sales Tax Act, 1956 are subject, by section 15(a), to State taxation at only one stage and within the prescribed rate limit. The Court held that the statutory phrase "last purchase in the State" in the State sales tax schedule must be read in the context of the full chain of successive sales or purchases, and not by artificially limiting the enquiry to the assessment year alone. The stage attracting levy is reached when the goods are at the final point before export outside the State or before consumption in manufacture, and the mere fact that the goods remain unsold at year-end does not by itself make the purchase the last purchase in the statutory sense. The Court rejected the contrary approach of treating the assessment year as the sole unit for identifying the levy stage, as that would permit multiple taxation and defeat the object of single point levy.

Conclusion: The assessment based only on the existence of unsold stock at the close of the year was improper, and the disputed turnover could not be taxed on that basis; the revision was rightly dismissed.

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