Export exemption on raw and dressed hides fails where the goods are legally distinct under sales tax law.

Raw hides and skins and dressed hides and skins are distinct commodities for export exemption under section 5(3) of the Central Sales Tax Act, 1956, so an assessee who purchases raw hides and exports dressed hides cannot claim exemption because the exported goods are not the same goods as those purchased. Section 14(iii) classifies declared goods but does not treat them as one commodity for all purposes. Departmental circulars bind the Revenue only so far as they remain consistent with the statute and later binding Supreme Court rulings; once the Supreme Court settled the position, the circulars could not prevail.

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Issues: Whether raw hides and skins and dressed hides and skins are the same commodity for the purpose of exemption on export sales under section 5(3) of the Central Sales Tax Act, 1956; and whether departmental circulars could override the effect of later Supreme Court authority on that question.

Analysis: The earlier view that raw hides and skins and dressed hides and skins could be treated as one commodity for export exemption under section 5(3) was examined in the light of later Supreme Court decisions. The controlling authority held that raw hides and skins and dressed hides and skins are distinct taxable commodities, and that section 14(iii) of the Central Sales Tax Act, 1956 merely classifies declared goods and does not treat them as one commodity for all purposes. On that basis, an assessee purchasing raw hides and skins and exporting dressed hides and skins cannot claim exemption under section 5(3), because the exported goods are not the same goods as those purchased. The circulars relied on by the assessee were held to bind the Revenue only to the extent they operate consistently with the statute and later binding judicial pronouncements; once the Supreme Court had settled the legal position, those circulars could not prevail.

Conclusion: The claim for exemption failed, and the assessee was not entitled to relief under section 5(3) of the Central Sales Tax Act, 1956.

Final Conclusion: The law was applied against the assessee on both the identity of the goods and the effect of the circulars, resulting in rejection of the revision and confirmation of tax liability.

Ratio Decidendi: Goods that undergo transformation from raw hides and skins into dressed hides and skins are not the same goods for purposes of export exemption under section 5(3) of the Central Sales Tax Act, 1956, and administrative circulars cannot override the binding effect of later Supreme Court rulings.

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