Classification of steel castings depended on commercial identity after processing, and the goods remained steel castings.

Steel castings retained their identity as steel castings where no substantial addition, improvement, or major processing after casting was shown to create a commercially different product. The Court found no material proving that the goods had been modified by added metals or other processing sufficient to alter their commercial character. As a result, the goods were not classifiable as "metallic products" under the First Schedule and were to be assessed as steel castings under entry 2(ii)(h) of the Second Schedule, in favour of the assessee.

---

---

Issues: Whether steel castings manufactured and sold by the petitioner were classifiable as "metallic products" under the First Schedule to the Kerala General Sales Tax Act, 1963, or as steel castings under entry 2(ii)(h) of the Second Schedule.

Analysis: The determining question was whether any substantial addition or improvement was made after the casting process so as to bring about a commercially different product. On the materials before the Court, there was no finding that the petitioner had carried out any such major modification or addition of other metals. The department also did not establish that the goods had undergone processing sufficient to change their character into a different commercial product. In these circumstances, the product retained its identity as steel casting.

Conclusion: The goods were not taxable as "metallic products" under the First Schedule. They were liable to be assessed as steel castings under entry 2(ii)(h) of the Second Schedule, in favour of the assessee.

---