Declared goods and single-point sales tax prevent taxation on resale after tax is already paid once

Steel pipes classified as declared goods under section 14 of the Central Sales Tax Act, 1956 were subject to the single-point levy imposed by section 15(a), which limited State taxation on intra-State sales or purchases and barred tax at more than one stage. Because tax had already been paid when the assessee purchased the steel pipes from a registered dealer, resale of the same goods could not attract sales tax again. The assessee was therefore not liable to pay sales tax on the resale of the steel pipes.

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Issues: Whether steel pipes, being declared goods, could be subjected to sales tax again on their resale by the assessee after tax had already been paid at the stage of purchase from a registered dealer.

Analysis: Steel pipes were found to fall within the category of declared goods under section 14 of the Central Sales Tax Act, 1956. Section 15(a) of that Act, as applicable to the relevant period, restricted State taxation on declared goods so that the tax on any sale or purchase inside the State could not exceed three per cent and could not be levied at more than one stage. Since the assessee had already paid tax when purchasing the steel pipes from a registered dealer, the same goods could not be taxed again on resale.

Conclusion: The assessee was not liable to pay sales tax on the resale of the steel pipes.

Ratio Decidendi: Declared goods under section 14 of the Central Sales Tax Act, 1956 are subject to a single-point levy under section 15(a), and once tax has been paid at one stage, further taxation on the same intra-State sale or purchase is barred.

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