Commercial identity test governs classification of processed rubber sheets as rubber products, not raw rubber.

Raw rubber sheets or RMA sheets are treated as rubber products for sales tax classification because processing such as preservation, coagulation, drying, grading and packing creates a commercially distinct and marketable commodity. Classification therefore depends on the article's commercial identity in trade, not merely its original raw form. On that basis, the Tribunal's view that the goods fell within entry 101 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 as rubber products was supported by the evidence and was not shown to be perverse, so the goods were not taxable only at the general rate applicable to raw rubber.

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Issues: Whether raw rubber sheets or RMA sheets are classifiable under entry 101 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 as rubber products, or whether they are liable only at the general rate as raw rubber.

Analysis: The determining factor was the commercial character of the goods. The material on record showed that latex or natural rubber is subjected to several processing stages before it emerges as RMA rubber sheets, including preservation, coagulation, drying, grading, and packing. The Court held that these processes bring about a commercially different and marketable product, distinct from latex or natural rubber. Authorities concerning processed commodities were relied upon to support the principle that goods derived through manufacturing or processing may lose their original identity for sales tax classification. The Tribunal's finding that the goods were rubber products and not raw rubber was treated as a factual finding based on evidence and not shown to be perverse.

Conclusion: Raw rubber sheets or RMA sheets fall under entry 101 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 as rubber products, and not under the general rate applicable to raw rubber.

Ratio Decidendi: Where a commodity undergoes processing that results in a commercially distinct and marketable product, its tax classification is determined by its identity in commercial parlance rather than by its original raw form.

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