Commercial commodity test treats perforated iron sheets as distinct goods, not declared iron and steel under sales tax law.

Perforated iron sheets were analysed under the commercial commodity test to determine whether they continued to fall within "iron and steel" as declared goods under section 14(iv) of the Central Sales Tax Act. The statutory entry covered specified iron and steel products, including plain and corrugated sheets, but did not expressly include perforated sheets. Because perforation altered the goods' identity, use and interchangeability, and the sheet could not be restored to its original form, the process produced a distinct commercial commodity. Perforated iron sheets were therefore treated as an unclassified item rather than declared goods.

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Issues: Whether iron sheets, after perforation of holes, continue to fall within "iron and steel" under section 14(iv) of the Central Sales Tax Act or become a different commercial commodity taxable as an unclassified item.

Analysis: The relevant statutory entry under section 14(iv) of the Central Sales Tax Act treated specified categories of iron and steel as declared goods. The amendment specifically brought plain and corrugated sheets within the entry, but perforated sheets were not expressly included. Applying the commercial commodity test, the decisive question was whether the process of perforation preserved the identity and use of the original goods. The Court held that a perforated sheet cannot be used in the same manner as a plain sheet, the two are not interchangeable in use, and the perforated sheet cannot be restored to its original form. On that basis, the process resulted in emergence of a distinct commercial commodity rather than a mere continuation of the original sheet.

Conclusion: Perforated iron sheets do not remain "iron and steel" under section 14(iv) of the Central Sales Tax Act and are liable to be treated as an unclassified item.

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