Declared goods treatment of wheat derivatives turns on express statutory naming and separate taxable classification of by-products.

Wheat is a declared good under the Central Sales Tax Act only to the extent expressly specified by name, and its separately identifiable derivatives maida, ravva, atta, sujji and bran are not automatically included within that description. Because the Andhra Pradesh General Sales Tax Act separately lists those commodities for single-point taxation, the statutory scheme supports treating them as distinct taxable goods rather than as wheat itself. The analysis also notes that market recognition of these by-products as separate commodities reinforces that conclusion, and earlier cases were distinguished on their facts and statutory context. Accordingly, State levy on these wheat derivatives under the Andhra Pradesh General Sales Tax Act is valid.

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Issues: Whether maida, ravva, atta, sujji and bran obtained from wheat are part of "wheat" as declared goods under the Central Sales Tax Act, 1956, or are separately taxable commodities under the Andhra Pradesh General Sales Tax Act, 1957.

Analysis: Wheat alone is specified as a declared good under section 14 of the Central Sales Tax Act, 1956. The by-products maida, ravva, atta, sujji and bran are not named in that provision, whereas the State Act separately lists those commodities in the First Schedule under section 5 for single-point taxation. The legislative scheme showed that where Parliament intended to include by-products, it did so expressly, but no such inclusion was made for wheat derivatives. The commodities were also treated in the market as distinct goods identifiable by their own names. Earlier decisions relied upon by the petitioners were distinguished as dealing with different commodities and different statutory settings.

Conclusion: The commodities maida, ravva, atta, sujji and bran are not to be treated as wheat for the purpose of declared goods, and their levy of sales tax under section 5 of the Andhra Pradesh General Sales Tax Act, 1957, is valid.

Ratio Decidendi: Goods are treated as declared goods only when expressly specified by name in the relevant statutory provision, and separately identifiable by-products not so specified may be subjected to State taxation under the applicable sales tax schedule.

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