Declared goods classification: C purlins from iron and steel inputs were separately taxable as distinct commodities.

C purlins manufactured from iron skelp and H.R. coils were treated as distinct commodities from the declared goods purchased, because the Third Schedule entry on "iron and steel" treated its sub-items as separate items for levy purposes. The Andhra Pradesh General Sales Tax Act did not contain any special exemption protecting sales of goods manufactured from those sub-items, and the dealer's reliance on other State decisions was distinguished on the basis of different statutory provisions. The manufactured goods were therefore liable to separate sales tax, and the argument that the statutory scheme barred such levy was rejected.

---

---

Issues: Whether the goods manufactured from iron skelp and H.R. coils, namely C purlins, remained the same declared goods falling within "iron and steel" so as to escape separate levy of sales tax under the Andhra Pradesh General Sales Tax Act, 1957.

Analysis: The entry relating to "iron and steel" in the Third Schedule of the State Act reproduces the corresponding Central entry with certain variations, and the sub-items are treated as distinct commodities for the purpose of levy. The goods purchased by the dealer fell under one sub-item, while the manufactured goods sold were covered by other entries. No provision of the State Act was shown to grant exemption for sales of goods manufactured out of the specified iron and steel sub-items. The decisions relied upon by the dealer were distinguished as turning on special provisions of the respective State enactments, whereas no comparable provision existed in the Andhra Pradesh Act.

Conclusion: The manufactured goods were different commodities and were liable to tax. The contention that the scheme of the Act barred levy was rejected.

---