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Issues: Whether tanned hides and skins sold in inter-State , having been obtained from locally purchased raw hides and skins already subjected to tax, constituted the same commodity for the purposes of levy under the Central Sales Tax Act, 1956.
Analysis: The decisive question was whether raw hides and skins and tanned hides and skins were to be treated as one commodity in view of the statutory scheme governing declared goods. The Court followed the earlier view that, for the purposes of the Central Sales Tax Act, hides and skins in raw or dressed form do not cease to be the same commodity merely because of processing, and relied on the interpretation placed on the relevant statutory provisions in the earlier binding decision covering the same issue.
Conclusion: The levy sustained by the Tribunal could not stand, and the revision was allowed in favour of the assessee.