Single-point sales tax on declared goods bars second levy once groundnuts were already taxed in the purchase chain.

Declared goods under a single-point sales tax scheme could not be taxed twice on the same groundnuts once tax had already been validly collected from one liable crushing miller in the purchase chain. Section 6 of the Andhra Pradesh General Sales Tax Act, 1957, read with item 3-C of Schedule IV, was treated as permitting tax only at the specified single point, so the taxing power was exhausted after lawful levy on the same goods. The distinction between first and last purchasing millers was not decisive where prior tax payment was shown, and evidence of such payment was admissible in assessment proceedings.

---

---

Issues: Whether groundnuts could be subjected to a second levy of sales tax from the petitioner when tax had already been collected from the crushing millers who purchased the goods from it, and whether item 3-C of Schedule IV read with section 6 of the Andhra Pradesh General Sales Tax Act, 1957 permitted such further assessment.

Analysis: Section 6 imposed tax on declared goods only at a single point of sale or purchase specified in the Schedule. The relevant schedule entries for groundnuts underwent changes, but the 1961 amendment did not fix tax rigidly at one particular miller as against another; instead, the scheme showed that once tax was collected at any lawful purchase point, the statutory power to tax the same goods was spent. The distinction between a first purchasing miller and a last purchasing miller was therefore not decisive where tax had already been levied on one of the millers dealing in the same groundnuts. The Court also accepted that evidence on prior payment of tax by the crushing millers should be received in the assessment proceedings.

Conclusion: If the crushing millers had already paid sales tax on the same groundnuts, the petitioner was not liable to pay tax again.

Ratio Decidendi: Under a single-point levy on declared goods, once tax is validly collected from one liable purchaser, the taxing authority cannot levy tax again on another purchaser in the same chain for the same goods.

---