Processed wheat products are not "wheat" for declared-goods protection; the tax notification was upheld.

Flour, atta, maida and suji derived from wheat are not covered by the expression "wheat" in section 14(i)(iii) of the Central Sales Tax Act, 1956 because they are distinct commercial commodities and would not ordinarily be bought as wheat in the market. The statutory scheme protects only goods specifically declared as goods of special importance, and section 15 applies only to such declared goods. Since the entry for wheat was read in its commercial sense and did not use expansive wording such as "in all its forms", processed wheat products were outside the declared-goods protection, and the Rajasthan notification levying tax on them was valid.

---

---

Issues: Whether flour, atta, maida and suji made from wheat are included in the expression "wheat" in section 14(i)(iii) of the Central Sales Tax Act, 1956 so as to be declared goods entitled to the protection of section 15, and whether the impugned Rajasthan notification levying tax on those products was invalid.

Analysis: The constitutional and statutory scheme treats only goods specifically declared under section 14 of the Central Sales Tax Act, 1956 as goods of special importance, with section 15 imposing restrictions on the State's taxing power only in relation to such declared goods. The expression "wheat" in section 14(i)(iii) was examined in the light of the structure of section 14, the contrasting drafting used elsewhere in that section such as "in all its forms" and "whether in a raw or dressed state", and the settled principle that taxing entries must be read in their commercial sense. The Court distinguished authorities dealing with rice, pulses and other commodities where the product retained the same commercial identity after simple processing. It held that flour, atta, maida and suji, although derived from wheat, are different commercial commodities and would not ordinarily be purchased as wheat in the market.

Conclusion: Flour, atta, maida and suji are not included in the term "wheat" in section 14(i)(iii) of the Central Sales Tax Act, 1956, section 15 does not apply to them, and the impugned notification was valid.

Ratio Decidendi: Where a goods entry in a taxing statute is exhaustively worded and does not use expansive language such as "in all its forms", processed products having a distinct commercial identity are not covered by the named commodity merely because they are manufactured from it.

---