Commercial identity test: M.S. rounds kept exemption, while angles and squares were treated as distinct taxable goods.

M.S. rounds retained the same commercial identity as the rounds originally purchased, so they qualified for exemption from single point taxation. The governing test was whether the goods sold remained the same commercial commodity that had already suffered tax; if processing or manufacture creates a different commercial commodity, the earlier tax does not extend to the new product. Applying that principle, M.S. angles and M.S. squares were treated as distinct commercial commodities under the relevant schedule, with angles falling under steel structurals and rounds and squares under steel bars. Accordingly, exemption was available only for M.S. rounds and not for M.S. angles or M.S. squares.

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Issues: Whether M.S. rounds sold by the assessee retained the same commercial identity as the M.S. rounds purchased earlier so as to qualify for exemption from single point taxation, and whether M.S. angles and M.S. squares produced from those rounds could also claim the same exemption.

Analysis: The relevant schedule treated steel bars and steel structurals as distinct entries, with rounds and squares falling under steel bars and angles under steel structurals. The deciding test was whether the goods sold remained the same commercial commodity as the goods that had already suffered tax. Once processing or manufacture brings into existence a different commercial commodity, the original tax suffered by the raw material does not carry over to the new product. On that principle, the rounds sold by the assessee remained commercially the same as the rounds purchased earlier, but the angles and squares emerged as different commercial commodities. The cited Supreme Court principles on retention of identity and emergence of distinct taxable goods support this approach.

Conclusion: M.S. rounds alone were entitled to exemption from tax, while M.S. angles and M.S. squares were not.

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