Declared goods and multiple taxation: iron wires made from taxed wire rods could not be subjected to a second sales tax.

Declared goods under the Central Sales Tax Act were treated as subject to a restriction against repeated taxation where wire rods and wires were grouped in the same entry. The Court reasoned that this grouping showed no legislative intent to impose a second sales tax on iron wires manufactured from wire rods already taxed, and distinguished cases involving commercially distinct commodities. On that basis, iron wires made from taxed wire rods were not liable to fresh sales tax, and the issue was resolved in favour of the assessee.

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Issues: Whether iron wires manufactured from wire rods could be treated as a separate taxable commodity for sales tax purposes, notwithstanding that wire rods and wires are grouped together in the declared goods entry.

Analysis: The statutory scheme for declared goods under Section 14 of the Central Sales Tax Act, 1956, read with the restriction on multiple taxation in Section 15 of that Act, was treated as controlling. The grouping of wire rods and wires in the same sub-item was taken to mean that the legislature did not intend wires to be subjected to a second levy where the wire rods had already suffered tax. The Court distinguished the rival line of decisions on commercially different commodities and held that the special treatment of declared goods prevented repeated taxation on the same goods in this setting.

Conclusion: Iron wires were not liable to be taxed again if the wire rods used for their manufacture had already suffered sales tax; the issue was decided in favour of the assessee.

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