Dual-stage taxation of closing timber stock upheld where amended scheme applied in a later assessment year.

Closing stock of timber brought forward from the earlier assessment year was held taxable under the amended scheme that imposed tax at two stages. The court accepted that the timber had already suffered tax at the first point of sale in the earlier year, but that prior position did not control the later year because the tax incidence had changed under a different assessment-year structure. The assessee's challenge therefore failed, and dual-stage taxation for the subsequent year was upheld.

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Issues: Whether the closing stock of timber carried forward from the earlier assessment year could be subjected to tax under the amended scheme resulting in taxation at two stages.

Analysis: The timber had been taxed at the first point of sale in the earlier year, whereas under the amended position for the subsequent year it became taxable at two stages. The prior decision on the same-year taxation of the same substance did not apply because the levy arose under a different assessment year and under a different tax incidence structure.

Conclusion: The closing stock of timber was validly taxable at both stages under the amended scheme, and the assessee's challenge failed.

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