Declared-goods relief depends on statutory identity; pipes, tubes and Hamilton poles were treated as distinct taxable commodities.

Declared-goods relief under the Central Sales Tax Act, 1956 is confined to goods that retain the same statutory identity as the taxed raw material. The text explains that section 14 lists iron and steel items in separate sub-clauses, and section 15(a) applies only where the raw material and finished product fall within the same declared-goods category. On that basis, pipes and tubes manufactured from iron and steel raw materials were treated as distinct commercial commodities and not covered by the relevant declared-goods entry. Hamilton poles were likewise treated as commercially different from strips and sheets. The deduction claims were therefore rejected.

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Issues: Whether pipes, tubes and Hamilton poles manufactured from taxed iron and steel raw materials retained the character of declared goods so as to qualify for deduction from gross turnover under the Bengal Finance (Sales Tax) Act, 1941 read with the Central Sales Tax Act, 1956.

Analysis: The statutory scheme under section 14 of the Central Sales Tax Act, 1956 treats the listed items of iron and steel as declared goods by separate sub-clauses, and the benefit of restricted taxation under section 15(a) applies only where the raw material and the finished product fall within the same declared-goods category. The governing principle is that sales tax is levied on commercial commodities, not on the substance from which they are made, and a distinct marketable product emerging from processing or manufacture is separately taxable even if the raw material had already suffered tax. Applying that principle, pipes and tubes were held not to fall within sub-clause (vi) or any other relevant sub-clause of section 14(iv), and Hamilton poles, being commercially different from strips and sheets, were also held not to retain the character of the original declared goods.

Conclusion: The claims for deduction were rightly rejected, as the finished goods were not entitled to treatment as declared goods for the purpose of exemption or deduction.

Ratio Decidendi: Separate entries in the declared-goods list under section 14 of the Central Sales Tax Act, 1956 denote distinct taxable commercial commodities, and tax relief under section 15(a) is available only when the raw material and the finished product fall within the same declared-goods category and retain the relevant statutory identity.

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