Paddy and rice are distinct commodities, so purchase tax applies to paddy even when the resulting rice is exported.

Paddy and rice were treated as distinct commodities in ordinary parlance because dehusking changes the identity of the goods and produces a separate marketable product. That distinction meant paddy remained a taxable commodity at the purchase stage, even though the rice manufactured from it was exported and therefore not subject to tax on export. The exemption or non-taxability of rice after processing did not exclude purchase tax on the original paddy.

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Issues: Whether paddy and rice are the same commodity or different commodities for the purposes of sales tax, and whether purchase tax on paddy was excluded because rice manufactured from it was exported and not taxable.

Analysis: Paddy and rice were held to be different commodities in ordinary parlance. Dehusking converts paddy into rice and brings about a change in the identity of the goods. Both are distinct marketable commodities. The absence of tax on export of rice did not alter the character of paddy as a taxable commodity at the stage of purchase.

Conclusion: Paddy and rice are different commodities, and paddy remained liable to purchase tax notwithstanding that the rice produced from it was exported.

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