Mere mixing of taxed ingredients does not create a new taxable commodity for sales tax purposes.

Masala powder, curry powder and rasam powder made by merely mixing ingredients that had already suffered sales tax did not constitute a commercially distinct new commodity. The process was only a convenience-based mixing exercise and did not bring into existence a different taxable product. On that basis, the concurrent findings of the appellate authorities were left undisturbed, and no further sales tax was payable on the powders.

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Issues: Whether masala powder, curry powder and rasam powder prepared by mixing ingredients that had already suffered sales tax in the State constituted a new commodity liable to sales tax.

Analysis: The ingredients used in the preparation had already suffered tax. The process involved only mixing of those ingredients for consumer convenience and did not result in the emergence of a commercially distinct product. The concurrent findings of the Appellate Assistant Commissioner and the Tribunal were based on an analysis of the process of preparation and there was no ground to disturb those findings.

Conclusion: The powders did not become a new commodity by mere mixing of taxed ingredients and were not liable to further levy of sales tax.

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