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Issues: Whether jowar, though in seed form, continued to be jowar for the purpose of levy of central sales tax as declared goods and, if so, whether in the absence of C forms the tax was chargeable at double the appropriate State sales tax rate.
Analysis: Jowar was treated as declared goods under section 14 of the Central Sales Tax Act, 1956. On the admitted local sales tax rate of 2 per cent, section 8(2)(a) made the central sales tax payable at double the State rate where the sale was without C forms. The Court also rejected the contention that jowar ceased to be jowar merely because it was in seed form, holding that its character as jowar remained unchanged.
Conclusion: Jowar remained jowar in seed form and attracted central sales tax at 4 per cent under section 8(2)(a) of the Central Sales Tax Act, 1956; the revision filed by the Revenue failed.
Ratio Decidendi: A declared commodity retains its identity notwithstanding its form, and in the absence of C forms the central sales tax is chargeable at twice the appropriate State sales tax rate under section 8(2)(a) of the Central Sales Tax Act, 1956.