Commercially distinct commodities: processed hides and skins could be taxed separately despite prior tax on raw hides and skins.

Raw hides and skins and dressed hides and skins were treated as commercially distinct commodities because curing, tanning and dressing bring a new marketable product into existence. The inclusion of both forms in the same declared-goods entry did not make them identical for sales tax purposes, and the statutory scheme did not bar taxation of the processed commodity. Section 14 was held to be classificatory, while Section 15 did not prevent levy on a different commodity emerging after manufacture. The State was therefore entitled to tax inter-State sales of dressed hides and skins despite prior tax on the purchase of raw hides and skins, and the challenge to the amended provision failed.

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Issues: Whether raw hides and skins and dressed hides and skins are different commodities for sales tax purposes, and whether the State could levy tax on inter-state sale of dressed hides and skins after tax had already been paid on the purchase of raw hides and skins.

Analysis: Raw hides and skins undergo a manufacturing process through curing, tanning and dressing before they emerge as dressed hides and skins. The Court held that the two are commercially distinct commodities and that the mere inclusion of both within Section 14(iii) of the Central Sales Tax Act does not make them one and the same commodity. Section 14 is only classificatory, while Section 15 restricts taxation of declared goods within a State; it does not prevent levy on a different commodity that emerges after processing. The earlier Constitution Bench decision was treated as establishing that raw and dressed hides and skins are different articles of merchandise, and the statutory scheme did not contain any provision treating them as a single commodity for tax purposes.

Conclusion: The State was entitled to levy sales tax on dressed hides and skins even though tax had been paid earlier on raw hides and skins, and the challenge to the amended State provision failed.

Final Conclusion: The appeals failed because the goods sold in dressed form were held to be a separate taxable commodity from raw hides and skins, so the impugned levy and amendment were upheld.

Ratio Decidendi: Where processing brings into existence a commercially distinct commodity, inclusion of both forms within the same declared-goods entry does not bar taxation of the processed form under the State sales tax law.

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