Taxability of tanning chemicals turns on factual proof of transfer of property, not on a general rule.

Consumable chemicals used in a tanning process attract tax under section 3B of the Tamil Nadu General Sales Tax Act, 1959 only if, on the facts, they retain identity or result in transfer of property in some surviving form. If the goods are wholly consumed, washed away, or lose their character without any remaining property, taxability is not established automatically. The inquiry is fact-sensitive and cannot be resolved on general principle alone. Because the record did not contain adequate factual findings on the chemicals' role in the tanning process, the existing order was unsustainable and the matter was remitted for fresh consideration with opportunity to produce supporting material.

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Issues: Whether the chemicals used in the tanning process involved transfer of property so as to attract tax under section 3B of the Tamil Nadu General Sales Tax Act, 1959, and whether the matter required fresh factual examination.

Analysis: The applicable test is whether the consumable goods used in the process retain any identity or whether they are consumed and lose their character entirely. If the goods, after use, continue to exist in some form or result in accretion to the finished product, transfer of property may be inferred. If they are completely washed away or consumed without any surviving property in any form, taxability does not automatically follow. The question is fact-sensitive and cannot be decided on general principle alone. In the present case, the factual materials regarding the tanning process and the exact role of the chemicals were not placed before the assessing authority or the appellate forums, and no adequate factual finding existed on how transfer of property, if any, occurred.

Conclusion: The existing order could not be sustained for want of factual findings, and the matter was remitted to the assessing authority for fresh consideration after giving the assessee an opportunity to produce supporting materials.

Ratio Decidendi: Whether consumable goods used in a process are taxable depends on a fact-specific inquiry into whether they are transferred in any form or are completely consumed without surviving identity.

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