Declared goods treatment of wheat extends to atta, maida and soji, barring repeated taxation on processed forms.

Atta, maida and soji obtained from wheat were treated as the same commodity as wheat because processing only changed the grain's form and size without adding any new ingredient or altering its essential character. Applying the common parlance and commercial identity tests, the processed products continued to fall within the declared goods entry for wheat under the Central Sales Tax Act, so the statutory restriction against multiple or higher-stage taxation applied. Tax could not again be levied under the Karnataka Sales Tax Act on atta, maida and soji produced from tax-paid wheat, as that would amount to repeated taxation of the same declared commodity contrary to Section 15 of the Central Sales Tax Act.

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Issues: (i) Whether atta, maida and soji obtained from wheat are the same commodity as wheat for the purpose of declared goods under the Central Sales Tax Act, 1956. (ii) Whether tax could be levied under the Karnataka Sales Tax Act, 1957 on atta, maida and soji produced from tax-paid wheat.

Issue (i): Whether atta, maida and soji obtained from wheat are the same commodity as wheat for the purpose of declared goods under the Central Sales Tax Act, 1956.

Analysis: Wheat is a declared good under Section 14 of the Central Sales Tax Act, 1956, and Section 15 of that Act restricts the levy on declared goods to one stage and to the prescribed rate. The products in question are obtained from wheat merely by reduction in size and form, without addition of any new ingredient and without alteration in their essential character. Applying the common parlance and commercial identity tests, and following the principle that a mere change in form does not create a commercially different commodity, atta, maida and soji remain wheat in substance.

Conclusion: Yes. Atta, maida and soji are not different from wheat and continue to fall within the declared goods entry of wheat.

Issue (ii): Whether tax could be levied under the Karnataka Sales Tax Act, 1957 on atta, maida and soji produced from tax-paid wheat.

Analysis: Once wheat has suffered tax as declared goods under Section 5(4) of the Karnataka Sales Tax Act, 1957, the same commodity in a changed form cannot be subjected again to tax under Section 5(3)(a) as if it were a separate goods. Such treatment would permit repeated and multi-point taxation of the same declared commodity and would be inconsistent with the restrictions contained in Section 15 of the Central Sales Tax Act, 1956. The levy and assessment treating atta, maida and soji as distinct goods were therefore unsustainable.

Conclusion: No. Tax could not be levied again on atta, maida and soji when the wheat out of which they were produced had already suffered tax.

Final Conclusion: The petitions succeeded because the processed wheat products retained the identity of wheat and were protected by the statutory restrictions applicable to declared goods.

Ratio Decidendi: Where a declared good is processed only into another form without addition or change in substance, the processed form remains the same commodity and cannot be subjected to repeated or multi-point taxation contrary to the restrictions governing declared goods.

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