Distinct tax classification of parched rice and puffed rice as separate commodities under the Karnataka sales tax scheme.

Under the Karnataka Sales Tax Act, separate schedule entries for parched rice, puffed rice and rice support distinct tax classification, so parched rice and puffed rice were not to be treated as rice for the claimed exemption or purchase tax treatment. A prior ruling treating rice and puffed or parched rice as the same commodity was distinguished because it arose under a different statutory scheme without separate classification. The analysis applies the principle that the Legislature may classify goods separately and that processing may produce a different commercial commodity for sales tax purposes.

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Issues: Whether parched rice and puffed rice are covered by the entry for rice under the Karnataka Sales Tax Act, 1957, so as to avoid purchase tax, despite the separate schedule entries for parched rice and rice.

Analysis: The Act separately enumerated parched rice and beaten rice in one schedule entry and rice in another. A prior decision treating rice and puffed or parched rice as the same commodity was distinguished because it proceeded on the scheme of a different statute that did not contain such separate classification. The Court applied the principle that the Legislature may classify goods distinctly, and that a manufacturing process may create a new commercial commodity for sales tax purposes. On the Karnataka statutory scheme, the separate entries showed that parched rice and puffed rice could not be treated as the same as rice for the purpose of the exemption or classification claimed by the dealer.

Conclusion: Parched rice and puffed rice are not to be treated as rice under the Karnataka schedule entries in issue, and the Tribunal's view was ely accepted the dealer's claim.

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