Copra falls within taxable coconuts under the amended sales tax entry, making the last purchaser liable.

Copra was treated as included within the expression "coconuts" under the amended explanation to Item 5 of Schedule III of the Andhra Pradesh General Sales Tax Act, because the definition expressly covered fresh or dried coconuts, shelled or unshelled, and included copra while excluding tender coconuts. On that wording, dried coconuts in shelled form fell within the taxable commodity, and the last point of purchase in the State operated as the point of taxation. Once converted into oil, the commodity ceased to remain coconut. The petitioners' authorities were distinguished for turning on different statutory language, and the levy on copra was upheld.

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Issues: Whether copra falls within the expression "coconuts" in Item 5 of Schedule III to the Andhra Pradesh General Sales Tax Act so as to be liable to sales tax at the last point of purchase.

Analysis: The amended explanation to the schedule defined "coconuts" to mean fresh or dried coconuts, shelled or unshelled, including copra, but excluding tender coconuts. On that wording, dried coconuts in shelled form were held to be copra, and the Legislature had deliberately used the words "shelled or unshelled" to make clear that copra was included within the taxable commodity. The last point of purchase within the State was treated as the point of consumption, and once the dried coconut was converted into oil it ceased to remain coconut. The authorities relied on by the petitioners were distinguished because they were concerned with different statutory language.

Conclusion: Copra is included within "coconuts" under the amended explanation and is exigible to sales tax at the last point of purchase. The levy was upheld against the petitioners.

Final Conclusion: The petitions failed because the taxing entry, as amended, covered copra and the petitioners were the last purchasers liable to tax.

Ratio Decidendi: Where a taxing entry expressly includes "shelled or unshelled" dried coconuts and copra, copra is taxable as part of the scheduled commodity at the last point of purchase.

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