Single scheduled tax entry prevents splitting lenses and frames into separate commodities for second-sale taxation.

Spectacles, lenses and frames falling within a single scheduled entry under the Andhra Pradesh General Sales Tax Act could not be artificially split into separate commercial commodities for repeated taxation. Because the entry grouped spectacles, goggles, glasses, lenses and frames as one class taxable at the single point, the sale of lenses and frames, whether separately or as part of spectacles, retained the same statutory character. The second sales exemption was therefore not liable to be denied on the ground that the goods were distinct commodities.

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Issues: Whether spectacles, lenses and frames covered by entry 107 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 could be treated as separate commercial commodities so as to deny exemption on second sales.

Analysis: Entry 107 groups spectacles, goggles, glasses, lenses and frames together as goods taxable at the single point under section 5. The turnover in question related to second sales of lenses and frames. The fact that lenses and frames were sold separately or assembled as spectacles did not alter their character for the purpose of the entry, because the constituent items were part of the same scheduled category. Support was drawn from the principle that where the statutory entry treats closely connected goods as part of one class, they cannot be split up and taxed again as independent commodities.

Conclusion: The goods could not be treated as separate commercial commodities for independent taxation, and the exemption on second sales was not liable to be disturbed.

Ratio Decidendi: Where a taxing entry groups constituent goods together for single-point levy, those goods cannot be artificially split into separate commercial commodities for imposing tax again on a second sale.

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