Declared goods treatment of copra triggers section 15 limits on State tax and requires reassessment of sales liability.

Copra is treated as an oil-seed and therefore as declared goods under the Central Sales Tax Act, so the restrictions in section 15 apply, including the limits on State taxation and the rule against multi-stage levy. Inter-State sales of copra must also be assessed under the local sales tax law in a manner consistent with that statutory scheme. The assessments therefore required reconsideration to determine whether the relevant sales were the only sales or the first sales in the series, and fresh assessment was directed on that basis.

---

---

Issues: (i) whether copra is an oil-seed and therefore declared goods within the meaning of the Central Sales Tax Act, 1956, attracting the restrictions in section 15; (ii) whether the assessments of inter-State sales of copra had to be made subject to section 3 of the General Sales Tax Act, 1125 read with section 15 of the Central Sales Tax Act, 1956.

Issue (i): whether copra is an oil-seed and therefore declared goods within the meaning of the Central Sales Tax Act, 1956, attracting the restrictions in section 15.

Analysis: Section 14 of the Central Sales Tax Act, 1956 treats oil-seeds as goods of special importance in inter-State trade. Copra falls within that description because it is an oil-bearing commodity. Once copra is treated as declared goods, the statutory restrictions in section 15 become applicable, including the limitation that tax on such goods inside the State cannot exceed the prescribed rate and cannot be levied at more than one stage.

Conclusion: Yes. Copra is declared goods as an oil-seed, and section 15 of the Central Sales Tax Act, 1956 applies.

Issue (ii): whether the assessments of inter-State sales of copra had to be made subject to section 3 of the General Sales Tax Act, 1125 read with section 15 of the Central Sales Tax Act, 1956.

Analysis: Liability under the local sales tax law remained relevant, but in the case of declared goods the levy had to conform to the restrictions imposed by section 15 of the Central Sales Tax Act, 1956. The tax liability on copra sales therefore depended on whether the sales were the only sales or the first sales in the series, and the assessments had to be reconsidered on that basis under section 3 of the General Sales Tax Act, 1125 read with section 15 of the Central Sales Tax Act, 1956.

Conclusion: The assessments required reconsideration in the light of the combined statutory scheme.

Final Conclusion: The matter was sent back for fresh assessment after applying the statutory restrictions governing declared goods, and the challenge to the assessments did not succeed outright.

Ratio Decidendi: Where a commodity is declared goods under section 14 of the Central Sales Tax Act, 1956, the State levy must comply with section 15, including the one-stage and rate restrictions, and the assessments must be made accordingly.

---