Declared goods cannot be taxed twice: State first-sale levy yields to Central Sales Tax limits on the same goods.

Declared goods are subject to the special restriction in section 15 of the Central Sales Tax Act, which limits State taxation to one point and a prescribed rate. Where the same goods had already suffered Central Sales Tax on an inter-State first sale, the State could not again treat a later intra-State sale of those identical goods as a fresh first sale under the local sales tax law. Section 6 of the local Act had to yield to the Central scheme, and the goods being delivered outside the State and later brought back did not create a new taxable chain for the same declared goods.

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Issues: Whether declared goods, which had already suffered tax under the Central Sales Tax Act on inter-State sales, could again be subjected to the State sales tax as first sales when the same goods were later sold inside the State.

Analysis: The local Act imposed a multi-point levy, but declared goods were governed by the special restriction in section 15 of the Central Sales Tax Act, which limited the State levy to one point and a prescribed rate. The Court held that where the earlier transaction was in substance the first sale inside the State and also an inter-State sale attracting Central Sales Tax, the State could not again treat a later sale of the same identical goods as a fresh first sale for local tax purposes. Section 6 of the local Act had to yield to section 15 of the Central Act, and the fact that the goods were delivered outside the State and later brought back did not create a new taxable chain for the same declared goods.

Conclusion: The subsequent sales inside the State were not liable to be taxed again as first sales under the local Act, and the assessee succeeded.

Final Conclusion: Declared goods that had already borne Central Sales Tax on the relevant inter-State first sale could not be subjected to an additional single-point levy under the State law on the same turnover.

Ratio Decidendi: Section 15 of the Central Sales Tax Act overrides the State levy in respect of declared goods and prohibits more than one point of taxation on the same sale transaction when the goods have already suffered tax at the relevant taxable stage.

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