Declared goods limit and tax interest upheld where processed steel cable trays were treated as distinct commodities.

Cable trays fabricated from steel sheets were held not to fall within the declared-goods expression "iron and steel" in section 14(iv)(vii) of the Central Sales Tax Act because the statutory list is exhaustive and the trays emerged as distinct commercial commodities after substantial processing, including cutting, punching, bending, welding and galvanizing. Interest under section 27(1) of the Delhi Sales Tax Act was also upheld because the returns were found not true and correct, the omission to disclose taxability was held willful, and no infirmity was shown in that finding. Both questions were answered in favour of the Revenue.

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Issues: (i) Whether cable trays manufactured from steel sheets were covered by the expression "iron and steel" under section 14(iv)(vii) of the Central Sales Tax Act, 1956; (ii) Whether the dealer was liable to pay interest under section 27(1) of the Delhi Sales Tax Act, 1975.

Issue (i): Whether cable trays manufactured from steel sheets were covered by the expression "iron and steel" under section 14(iv)(vii) of the Central Sales Tax Act, 1956.

Analysis: The expression "that is to say" in section 14 makes the enumerated categories exhaustive. Goods not expressly covered by the specified sub-clauses cannot be treated as declared goods merely because they are made from iron or steel. Applying the commercial identity and transformation tests, the Court held that perforated and ladder-type cable trays are distinct commercial commodities, manufactured through cutting, punching, bending, welding and galvanizing of steel sheets. They are not plain or chequered plates and cannot be brought within clause (vii).

Conclusion: The issue was decided against the assessee and in favour of the Revenue.

Issue (ii): Whether the dealer was liable to pay interest under section 27(1) of the Delhi Sales Tax Act, 1975.

Analysis: Interest under section 27(1) follows statutory default in payment of tax due. The Tribunal had found that the returns were not true and correct and that the omission to disclose taxability was willful. In the absence of any infirmity in that finding, the liability to interest was upheld.

Conclusion: The issue was decided against the assessee and in favour of the Revenue.

Final Conclusion: Both referred questions were answered in the affirmative in favour of the Revenue, and the assessee's challenge failed.

Ratio Decidendi: A product made by substantial processing that emerges as a distinct commercial commodity is not covered by a limited declared-goods entry merely because it is manufactured from the enumerated material, and statutory interest on tax default is payable where the return is found to be incorrect and the default is not bona fide.

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