Retrospective classification of processed dal as distinct foodgrain makes first purchase liable to purchase tax.

A retrospective amendment to section 3-D treated split or processed foodgrains, including dal, as distinct from unsplit or unprocessed foodgrains, with the result that the first purchase of processed dal became separately taxable. The legal effect was that earlier taxation of the unsplit form did not prevent purchase tax on the first purchase of the processed form. Where the assessee was the first purchaser of processed dal, the turnover was exigible to purchase tax. The issue was answered in the affirmative, confirming tax liability on purchases of processed dal.

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Issues: Whether purchases of split or processed dal were liable to purchase tax as first purchases in the assessee's hands after the retrospective amendment to section 3-D of the Act.

Analysis: By the amendment, split or processed foodgrains such as dal were deemed to be different from unsplit or unprocessed foodgrains, and the provision was made retrospective. The legal effect of the amendment was that the first purchase of processed dal became independently taxable notwithstanding earlier taxation of the unsplit form. Since the assessee was the first purchaser of the processed dal, the turnover was exigible to purchase tax.

Conclusion: The question was answered in the affirmative. The assessee was liable to purchase tax on the purchases of processed dal.

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