Declared goods doctrine bars purchase tax on split pulses treated as the same commodity as whole pulses.

Pulses are declared goods under the Central Sales Tax Act, and Parliament's mandate under section 15(d) requires whole pulses and split pulses to be treated as a single commodity for State tax purposes. Because the separated form does not become a distinct taxable commodity, the State cannot levy purchase tax by treating split pulses differently from whole pulses under the M.P. General Sales Tax Act. The statutory restriction on State taxing power therefore bars a second levy on the same declared goods.

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Issues: Whether, in view of section 15(d) of the Central Sales Tax Act, 1956, whole pulses and split pulses are to be treated as a single commodity so as to bar levy of purchase tax under section 7(1)(b) and section 7(2) of the M.P. General Sales Tax Act, 1958.

Analysis: Pulses fall within declared goods under section 14(vi-a) of the Central Sales Tax Act, 1956, and the State's taxing power is subject to the restrictions imposed by Parliament under article 286(3) of the Constitution of India. Section 15(d) expressly provides that each of the pulses referred to in section 14(vi-a), whether whole or separated and with or without husk, shall be treated as a single commodity for the purposes of levy of tax under the State law. On that basis, split pulses do not become a separate commodity for tax purposes, and the statutory fiction prevents a second levy in the form of purchase tax on the same declared goods.

Conclusion: Split pulses and whole pulses are one commodity for taxation purposes, and purchase tax under section 7(1)(b) and section 7(2) of the M.P. General Sales Tax Act, 1958 cannot be levied on such pulses.

Ratio Decidendi: Where Parliament has mandated that declared goods and their separated form constitute a single commodity, the State cannot impose purchase tax by treating the processed form as a distinct taxable commodity.

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