Purchase tax on turmeric processing fails where conversion into powder does not create a different commodity.

Purchase tax under section 7-A of the Tamil Nadu General Sales Tax Act was held inapplicable where turmeric bought from agriculturists was converted into turmeric powder. The levy applies only when purchased goods are consumed in the manufacture of a different commodity for sale. On the facts noted, the conversion did not amount to manufacture of another goods; turmeric remained turmeric in a changed form. The statutory condition for purchase tax was therefore not met, and the assessment was unsustainable.

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Issues: Whether purchase tax under section 7-A of the Tamil Nadu General Sales Tax Act, 1959 was payable on turmeric purchased from agriculturists and converted into turmeric powder.

Analysis: Liability under section 7-A arises when purchased goods are consumed in the manufacture of other goods for sale. On the facts found, conversion of turmeric into powder did not amount to consumption of the turmeric in the manufacture of a different commodity. The commodity remained turmeric, only in a changed form, and the statutory condition for levy was therefore not satisfied.

Conclusion: Section 7-A was not attracted, and the purchase tax assessment was unsustainable.

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