Declared goods classification turns on commercial identity; mere pre-painting of steel sheets does not create a new commodity.

Pre-painted galvanized steel metal sheets remain within the declared goods entry in Section 14(vi) of the Central Sales Tax Act unless processing changes their commercial identity into a different commodity. The key principle applied is that painting or other finishing does not, by itself, remove goods from the statutory description when they retain their original character. The clarification treating the sheets as taxable at 14.5% under the Karnataka Value Added Tax Act was therefore set aside, and the matter was remitted to the Commissioner for reconsideration in accordance with law.

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Issues: Whether pre-painted galvanized steel metal sheets continue to fall within the declared goods entry under Section 14(vi) of the Central Sales Tax Act, 1956, and whether the clarification treating them as taxable at 14.5% under the Karnataka Value Added Tax Act, 2003 could be sustained.

Analysis: Section 14 of the Central Sales Tax Act, 1956 identifies declared goods, and the relevant clause covers sheets, hoops, strips and skelp, both black and galvanized, hot and cold rolled plain and corrugated. The governing principle is that goods do not cease to be of their original description merely because they undergo processing or finishing, unless the processing changes their commercial identity into a different commodity. The distinction drawn by the authority was based mainly on the fact that the goods were pre-painted and ready for use, but that circumstance by itself did not establish that they became a commercially different commodity. The clarification therefore required reconsideration on the basis of the statutory entry and the effect of processing on identity.

Conclusion: The clarification was set aside and the matter was remitted to the Commissioner for reconsideration in accordance with law.

Ratio Decidendi: Mere painting or other finishing of declared goods does not take them out of the statutory entry unless their commercial identity is shown to have changed into a new commodity.

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