Exemption for ragi extends to ragi flour when grinding does not create a distinct taxable commodity.

Ragi flour was treated as the same exempt commodity as ragi under the Karnataka Sales Tax Act because ragi is listed in entry 40A of the Fifth Schedule and goods in that Schedule are exempt under section 8. The Court reasoned that grinding ragi into flour did not create a distinct commercial commodity, and there was no separate entry for ragi flour. It distinguished the Central Sales Tax Act scheme on the basis that the present Act did not contain separate entries for ragi flour. A later departmental notification exempting ragi flour was also noted as consistent with this interpretation, making the assessment and demand unsustainable.

---

---

Issues: Whether ragi flour is a separate taxable commodity under section 5(1) of the Karnataka Sales Tax Act, 1957, or only a form of ragi covered by the exemption for entry 40A of the Fifth Schedule.

Analysis: Ragi is specifically included in entry 40A of the Fifth Schedule, and goods in that Schedule are exempt from tax under section 8. There is no separate entry for ragi flour. The Court applied the principle that where a commodity is listed in an exemption schedule, a mere change in form by grinding does not necessarily create a distinct commercial commodity. The reasoning in the decision dealing with rice in altered form was treated as applicable, while the reasoning based on the scheme of sections 14 and 15 of the Central Sales Tax Act was held inapposite because the present Act did not contain separate entries for ragi flour. The later departmental notification exempting ragi flour was also noticed as supporting the same understanding of the statutory scheme.

Conclusion: Ragi flour is not a separately taxable commodity and is entitled to the same exemption as ragi; the assessment and consequential demand were unsustainable.

---