Commercial identity of strips and skelp preserved after cold rolling, preventing fresh tax as different commodities.

Processed strips and skelp did not become a new commercial commodity merely because they were cold rolled and reduced in width or thickness. The Third Schedule entry covering sheets, hoops, strips and skelp was treated as referring to the same commercial categories, and the descriptive words did not create separate taxable goods. Applying the charging scheme under Section 6 of the Andhra Pradesh General Sales Tax Act, 1957, read with the Third Schedule, declared goods remained taxable only at the specified point of sale. As the process only reduced size and the resultant product continued to be strip or skelp, the goods retained their original schedule identity and were not liable to fresh tax. The revision cases therefore failed.

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Issues: Whether strips and skelp purchased as declared goods, after cold rolling and reduction in width or thickness, remained the same commercial commodities covered by the Third Schedule entry, or became different commodities liable to fresh tax.

Analysis: The relevant entry in the Third Schedule covered sheets, hoops, strips and skelp, and the descriptive words following them did not create separate commercial categories. The charging scheme under Section 6 of the Andhra Pradesh General Sales Tax Act, 1957, read with the Third Schedule, subjected declared goods to tax only at the specified point of sale. The Court held that if the process merely reduced the size of a strip or skelp and the resultant product continued to be a strip or skelp, it could not be treated as a different commodity. The processing by cold rolling did not, on the facts, convert the goods into a new commercial article.

Conclusion: The processed strips and skelp continued to fall within the same schedule entry and were not liable to be treated as distinct commodities; the revision cases were liable to fail.

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