Declared goods taxation upheld as a single-point levy where the charging scheme itself identified the taxable sale stage.

Delhi sales tax law on declared goods was analysed as a single-point levy consistent with section 15(a) of the Central Sales Tax Act because the charging scheme, read harmoniously, confined tax to the last sale to an unregistered dealer or consumer. Earlier sales to registered dealers remained outside the levy, so express words such as "first sale" or "last sale" were not required. The absence of a separate certificate mechanism, knowledge provision, or express exclusion from gross turnover was also treated as immaterial, since the statutory structure itself showed when liability arose and prevented a second levy.

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Issues: (i) Whether the Delhi sales tax scheme fixed a lawful single stage of taxation for declared goods so as to comply with section 15(a) of the Central Sales Tax Act, 1956. (ii) Whether the absence of an express machinery for knowledge, certificates, or exclusion from gross turnover made the levy on declared goods invalid.

Issue (i): Whether the Delhi sales tax scheme fixed a lawful single stage of taxation for declared goods so as to comply with section 15(a) of the Central Sales Tax Act, 1956.

Analysis: The restriction in section 15(a) requires that declared goods not be taxed at more than one stage, but it does not insist that the State law must expressly use the words "first sale" or "last sale". The stage of levy may be gathered from the scheme of the charging provision itself. Reading section 5(2)(a)(ii) of the Delhi Act harmoniously with section 15(a), the taxable event was held to be the last sale in the series, namely a sale by a registered dealer to an unregistered dealer or consumer. Earlier sales to registered dealers remained outside the levy, and the scheme therefore operated as a single-point levy.

Conclusion: The Delhi Act was held to be consistent with section 15(a) on the question of the stage of taxation, and this contention failed.

Issue (ii): Whether the absence of an express machinery for knowledge, certificates, or exclusion from gross turnover made the levy on declared goods invalid.

Analysis: The absence of a separate statutory certificate or refund-style machinery did not invalidate the levy, because the dealer himself could ascertain from the statutory scheme whether he was the last seller and therefore liable. The Court distinguished the Punjab Act considered in Bhawani Cotton Mills and treated the Delhi Act as different in structure. It also held that once the liability itself did not arise on a prior taxed sale, the sale price of such goods need not be included in gross turnover merely because the statute did not contain an express exclusion clause. The combined operation of the Delhi Act and section 15(a) was sufficient to deny a second levy.

Conclusion: The levy was not invalid for want of a separate knowledge mechanism, certificate, or express exclusion from gross turnover, and this contention also failed.

Final Conclusion: The declared goods scheme under the Delhi Act was upheld as a valid single-point levy governed by the Central Sales Tax restrictions, while the assessees' challenge to the assessments failed and the Commissioner's writs succeeded.

Ratio Decidendi: A State sales tax law complies with section 15(a) of the Central Sales Tax Act, 1956 if its charging scheme, read harmoniously with that provision, clearly confines declared goods to one taxable stage, even without expressly naming that stage or providing a separate machinery for certificates or exclusion from turnover.

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