G.I. barbed wire is a distinct commercial commodity from G.I. wire and falls outside declared goods treatment.

Conversion of G.I. wire into G.I. barbed wire results in a commercially distinct commodity because twisting the wire and adding sharp edges gives the product a different function and commercial identity. On that principle, the two goods are not the same for the purposes of the declared goods list under section 14 of the Central Sales Tax Act, 1956, and G.I. barbed wire falls outside entry (xv) of clause (iv). Accordingly, section 15 does not apply to the converted product, and the issue was answered against the assessee and in favour of the Revenue.

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Issues: Whether conversion of G.I. wires into G.I. barbed wires resulted in a new commercial commodity so as to take the goods outside entry (xv) of clause (iv) of section 14 of the Central Sales Tax Act, 1956 and render section 15 inapplicable.

Analysis: Entry (iv) of section 14 of the Central Sales Tax Act, 1956 treats specified categories of iron and steel as declared goods, but the specification is confined to the particular goods described. Conversion of G.I. wire into G.I. barbed wire involves twisting the wire and fixing sharp edges so that the resulting product serves a different function and acquires a distinct commercial identity. Applying the principle that goods cease to be of one taxable description when they emerge as a commercially different commodity, G.I. barbed wire cannot be treated as the same commodity as G.I. wire for the purposes of declared goods.

Conclusion: G.I. barbed wire is a different commercial commodity from G.I. wire and is not covered by entry (xv) of clause (iv) of section 14 of the Central Sales Tax Act, 1956. The question was answered in the affirmative, against the assessee and in favour of the Revenue.

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