Declared goods and single-point taxation: mere groundnut decortication does not make a dealer a miller for sales tax purposes.

Declared goods under the Andhra Pradesh General Sales Tax Act had to be construed consistently with section 15(a) of the Central Sales Tax Act so that single-point taxation was preserved. The word "miller" in item 3 of Schedule IV was read in its contextual sense as a person who crushes groundnuts and extracts oil, not one who merely decorticates groundnuts and sells kernel. A broader reading would have created uncertainty in the taxable stage and risked multiple taxation of the same goods. On that construction, a mere decorticator was not a "miller" and the impugned assessments could not stand.

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Issues: Whether the word "miller" in item 3 of Schedule IV of the Andhra Pradesh General Sales Tax Act, 1957, included a person who merely decorticated groundnuts and sold kernel, so as to subject such purchase to tax at the miller stage, and whether such construction would accord with section 15(a) of the Central Sales Tax Act, 1956.

Analysis: The statutory scheme treated groundnuts as declared goods taxable only at a single point, and the point of levy had to be determined consistently with the restrictions imposed by section 15(a) of the Central Sales Tax Act, 1956. A construction that treated every decorticator as a miller would create uncertainty as to the taxable stage and could expose the same goods to taxation at more than one point after pooling and resale, contrary to the scheme of single-point levy. Reading the entry as a whole, the expression "miller" was understood in its contextual sense as a person who crushes groundnuts and extracts oil, that is, one who destroys the identity of the goods by milling. The earlier view that the first miller was taxable irrespective of whether he crushed the goods was not accepted.

Conclusion: A person who merely decorticates groundnuts is not a "miller" within item 3 of Schedule IV, and the impugned assessments could not be sustained against the petitioner.

Ratio Decidendi: Where a sales tax entry dealing with declared goods is capable of two meanings, it must be construed in harmony with the Central Sales Tax Act so as to preserve single-point taxation and prevent the same goods from being taxed more than once.

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