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Issues: Whether stranded rods are the same as wire rods for the purpose of classification as declared goods under the Central Sales Tax Act, and whether they are entitled to the concessional rate of tax.
Analysis: The relevant entry in section 14 of the Central Sales Tax Act, 1956 lists iron and steel items separately, and the statutory scheme shows that each specified item is treated as a distinct taxable commodity. The controlling test is how the goods are understood in common market parlance and whether they retain the same commercial identity. Applying that test, the Court found that stranded rods are not ordinarily treated in the market as wire rods merely because they are made from wire rods. The entry for wire rods cannot be expanded to include a specialised product not specifically enumerated, especially when the provision is to be strictly construed and the object of the declared-goods scheme is to confine the concessional treatment to the listed items.
Conclusion: Stranded rods are not wire rods for the purpose of section 14 of the Central Sales Tax Act, 1956, and the concessional rate was rightly denied.
Ratio Decidendi: Where a sales tax statute enumerates specified goods as separate sub-categories, classification depends on their accepted market identity, and a commodity not specifically listed cannot be brought within an entry by mere similarity of origin or manufacture.