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Issues: Whether copra is an oil-seed within the meaning of section 14 of the Central Sales Tax Act, 1956, so as to attract the treatment of declared goods and be taxable only at the specified single point.
Analysis: The expression "oil-seeds" was held to cover only seeds which retain the character of a seed and, without substantial processing, yield non-volatile oil. Applying the popular meaning of the term, an article that has lost the property of a seed cannot be treated as an oil-seed merely because oil may be extracted from it. Copra was found not to answer that description.
Conclusion: Copra is not an oil-seed within section 14 of the Central Sales Tax Act, 1956, and the challenge to the sales tax assessment failed.