Same goods principle applied to cold rolled and hot rolled steel strips under the sales tax schedule.

Cold rolled steel strips manufactured entirely from hot rolled steel strips were treated as the same goods for sales tax purposes because both products fell within the same entry in the Third Schedule to the Andhra Pradesh General Sales Tax Act, 1957. The decisive factual basis was that the hot rolled strips had already suffered tax in the State, and there was no legal basis to classify the processed strips as a different for the Act. On that reasoning, the goods were correctly treated as identical for tax treatment, and the tax revision cases failed.

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Issues: Whether cold rolled steel strips manufactured out of hot rolled steel strips, both falling under the same entry in the Third Schedule to the Andhra Pradesh General Sales Tax Act, 1957, were to be treated as the same goods for sales tax purposes.

Analysis: The cold rolled strips were found, as a fact, to have been manufactured entirely out of hot rolled strips that had already suffered tax in the State. Since both products fell within the same entry in the Third Schedule, there was no basis to treat them as different goods for the purpose of the Act.

Conclusion: The goods were correctly treated as the same goods, and the tax revision cases failed.

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