Preservation processing of raw hides and skins did not alter identity, preserving export benefit under sales tax law.

Raw hides and skins that were processed only for preservation before export retained their essential identity and remained covered by section 14(iii) of the Central Sales Tax Act, 1956. The tribunal treated the phrase "hides and skins, whether in a raw or dressed state" as extending through relevant stages of processing so long as the commodity's essential character was unchanged, and relied on contemporaneous administrative interpretation as a guide to meaning. On the facts, the department failed to show that the exported goods had become a different commodity from the one purchased, so the assessee remained entitled to the export-related benefit under section 5(3).

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Issues: Whether raw hides and skins, after processing undertaken for preservation before export, retained their identity as hides and skins so as to entitle the assessee to the benefit of section 5(3) of the Central Sales Tax Act, 1956.

Analysis: The expression "hides and skins, whether in a raw or dressed state" in section 14(iii) of the Central Sales Tax Act, 1956 was treated as covering the commodity through its relevant stages of processing, so long as its essential character remained the same. The Court relied on the accepted administrative clarification and the earlier interpretation that contemporaneous exposition by the competent authority is a useful guide to statutory meaning. On the facts, the processing was only for preservation and the department could not show that the exported commodity had become a different commodity from the one purchased.

Conclusion: The raw hides and skins did not lose their identity by the processing undertaken, and the assessee was entitled to the benefit of section 5(3) of the Central Sales Tax Act, 1956. The revision therefore failed.

Final Conclusion: The tax levy was not sustained and the revision was rejected, leaving the assessee's entitlement to the export-related benefit intact.

Ratio Decidendi: Where processing is merely for preservation and does not alter the essential identity of hides and skins, the commodity remains covered by section 14(iii), and the export-related benefit under section 5(3) cannot be denied on the ground of change in nature.

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