Declared goods classification: bent steel tubes used as exhaust pipes could not be taxed as motor vehicle parts.

Steel tubes supplied as bent exhaust pipes retained their essential commercial identity as declared goods, because specification, bending, or later use in a motor vehicle did not alter their character. The State could not reclassify them as motor vehicle parts or accessories merely by reference to their end use, and the higher tax entry therefore could not override the treatment applicable to declared goods. The operative principle is that goods with an unchanged basic identity remain within the declared goods category despite adaptation for a buyer's requirements.

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Issues: Whether exhaust pipes supplied as bent steel tubes for use in motor vehicles retained their character as steel tubes and declared goods, or could be taxed as parts or accessories of motor vehicles at a higher rate under the State sales tax law.

Analysis: The supply consisted of steel tubes made to specification and bent to suit the buyer's requirements. Their basic physical character remained that of steel tubes, and neither the description adopted by the buyer nor the use to which the buyer later put them altered that character. The fact that the tubes were fitted into an engine or chassis as exhaust pipes did not change the nature of the goods sold. Declared goods cannot be subjected to a higher rate of tax by re-describing them according to their end use, because the State is bound by the parliamentary declaration governing goods of special importance in inter-State trade or commerce. The taxing entry for motor vehicle parts and accessories could not therefore override the treatment applicable to declared goods.

Conclusion: The exhaust pipes were steel tubes falling within the declared goods entry, and their sale could not be taxed at the higher rate applicable to parts or accessories of motor vehicles. The assessee succeeded.

Final Conclusion: The classification adopted by the revenue was unsustainable, and the writ petition was allowed.

Ratio Decidendi: Where goods retain their essential commercial identity as declared goods, their subsequent bending, specification, or end use does not permit the State to reclassify them under a higher-tax entry by reference to their ultimate application.

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