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Issues: Whether ravva obtained from rice or wheat and fried Bengal gram are declared goods within section 14 of the Central Sales Tax Act, 1956 so as to attract the restrictions in section 15(a) of that Act and displace entries 144 and 147 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957.
Analysis: The declared-goods provisions in section 14 of the Central Sales Tax Act, 1956 were held to be exhaustive and to cover only the goods specifically named therein. The use of the words "that is to say" was treated as limiting the enumeration and not as extending it to commodities manufactured from, or obtained out of, the declared goods. Ravva, though derived from rice or wheat, and fried Bengal gram were treated as commercially different commodities from rice, wheat, gram or gulab gram. The Court applied the commercial identity and common parlance approach, and held that the fact that the raw material had itself been taxed did not make the resultant commodity a declared good. The restrictions in section 15(a) therefore did not apply to the goods covered by entries 144 and 147.
Conclusion: Entries 144 and 147 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 were held intra vires, and the impugned commodities were not declared goods under section 14 of the Central Sales Tax Act, 1956.