Separate tax classification for rough and polished granite stones defeats exemption claim under export-related sales tax provisions.

Rough granite stones and polished granite stones were treated as different commercial commodities for sales tax purposes because the Andhra Pradesh General Sales Tax Act, 1957 created separate schedule entries for each. Granite stones, boulders and chips fell under one entry, while polished granite stones were specifically covered under another, showing legislative recognition of distinct goods. On the admitted facts, the petitioners sold rough granite stones that were later polished and cut by export units before export, so the statutory basis for treating the goods as the same commodity was absent. The claim to exemption under section 5(3) of the Central Sales Tax Act, 1956 therefore failed.

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Issues: Whether rough granite stones and polished granite stones were the same commodity for sales tax purposes, and whether the turnover relating to such goods was exempt under section 5(3) of the Central Sales Tax Act, 1956.

Analysis: The relevant schedule entries under the Andhra Pradesh General Sales Tax Act, 1957 separately dealt with granite stones and polished granite stones. Entry 32 covered granite stones, boulders and chips at the point of last sale in the State, while entry 92 specifically covered polished granite stones at the point of first sale in the State. On the admitted facts, the petitioners sold rough granite stones, which were later polished and cut by export units before export. The existence of distinct statutory entries showed legislative recognition that rough granite stones and polished granite stones were different commercial commodities. The authorities relied on by the petitioners were distinguished because they concerned cases where no separate entries existed for the processed commodity, whereas here the statutory scheme itself treated the goods separately. The claim to exemption under section 5(3) therefore failed on the facts and statutory scheme.

Conclusion: Rough granite stones and polished granite stones were held to be different commodities, and the exemption claim was rejected.

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