Commercial identity of hides and skins controls CST exemption; raw and tanned goods are not automatically the same commodity.

Inter-State sales of tanned hides and skins were not exempt because the local tax had been paid on raw hides and skins, and the two stages were treated as commercially distinct commodities under the State sales tax law. Although section 14 of the Central Sales Tax Act places raw and tanned hides and skins in the same declared-goods category, that classification did not displace the local law's separate treatment or create identity between the goods taxed locally and the goods sold in inter-State trade. Relief under the exemption required complete identity of goods, so the inter-State sales of tanned hides and skins remained taxable.

---

---

Issues: Whether inter-State sales of tanned hides and skins were entitled to exemption on the footing that raw hides and skins and tanned hides and skins constituted the same commodity for the purposes of the Central Sales Tax Act and the State sales tax law.

Analysis: The local law treated raw hides and skins and dressed or tanned hides and skins as different taxable commodities, with different points of levy and different rates. The exemption under the Government Order could be claimed only where there was identity between the goods on which local tax had been paid and the goods sold in the course of inter-State trade. Although section 14 of the Central Sales Tax Act groups hides and skins at the raw and tanned stages as declared goods, that grouping did not override the commercial distinction recognised under the State enactment. The Court followed the earlier binding view that raw hides and skins and tanned hides and skins are commercially distinct, and that payment of tax on raw hides and skins does not automatically exempt inter-State sales of tanned hides and skins.

Conclusion: The exemption was not available and the inter-State sales of tanned hides and skins were taxable.

Ratio Decidendi: For relief under section 15(b) of the Central Sales Tax Act, there must be complete identity between the locally taxed goods and the goods sold in inter-State trade; mere inclusion of raw and tanned hides and skins in the same declared-goods entry does not make them commercially the same commodity.

---