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Issues: Whether stainless steel fell within the declared goods specified in Section 14 of the Central Sales Tax Act, and whether the turnover of stainless steel was therefore taxable only at the lower rate applicable to declared goods.
Analysis: Section 14, as it stood prior to the 1972 amendment, enumerated the categories of iron and steel goods in separate and distinct sub-items. The enumeration was exhaustive, and each specified item retained its own commercial identity for the purpose of single-point taxation in a series of sales. The mere fact that stainless steel is a form of steel did not bring it within the listed categories, because the provision did not treat all steel products as one composite commodity for tax purposes. Since stainless steel was not specifically mentioned in the list, it could not claim the status of declared goods under that clause.
Conclusion: Stainless steel was not covered by Section 14 of the Central Sales Tax Act and was not entitled to the tax treatment applicable to declared goods. The higher rate of tax was therefore payable on its turnover, and the revision succeeded only to that extent.
Final Conclusion: The decision settled that goods must fall within a specifically enumerated category in the declared-goods provision to receive the concessional single-point tax treatment, and a broadly similar metal product is not covered unless expressly included.
Ratio Decidendi: Where a statute exhaustively enumerates declared goods in separate categories, each category is a distinct taxable class for single-point taxation, and goods not expressly included cannot claim the benefit merely because they are commercially related.