Cardamom treated as an oil-seed under sales tax law, limiting it to single-point taxation as declared goods.

Cardamom was held to fall within the statutory definition of oil-seeds in section 14(vi) of the Central Sales Tax Act because it yields oil and the material showed that cardamom oil is obtained and used for flavouring and medicinal purposes. The statutory test covered seeds yielding non-volatile oils for human consumption or industry, as well as volatile oils used chiefly in medicines, perfumes, cosmetics and similar uses. On that basis, and supported by departmental treatment of cardamom as an oil-seed, cardamom was treated as declared goods taxable only at the permissible single point, not as general goods under a multi-point levy.

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Issues: Whether cardamom is an oil-seed within section 14(vi) of the Central Sales Tax Act and, if so, whether its turnover could be taxed as general goods at multi-point levy in the State.

Analysis: The determination could not rest merely on personal knowledge or on the common-parlance test in the abstract. Cardamom yields oil from its seeds and fruits, and the material relied on showed that cardamom oil is obtained and used for flavouring and medicinal purposes. The statutory definition of oil-seeds in section 14(vi) covers seeds yielding non-volatile oils used for human consumption or in industry, as well as volatile oils used chiefly in medicines, perfumes, cosmetics and the like. On the evidence noticed, cardamom fell within that statutory description. Departmental treatment of cardamom as an oil-seed also supported this view.

Conclusion: Cardamom is an oil-seed within section 14(vi) of the Central Sales Tax Act and is declared goods taxable only at the permissible single point. The turnover could not be assessed as general goods at multi-point levy, and the petitioners succeeded.

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