Declared goods treatment for stainless steel sheets limits tax, while finished utensils stay under schedule-based taxation.

Stainless steel sheets were treated as declared goods within the iron and steel scheme because departmental clarification and the later amendment brought tool alloy and special steels within that category, so tax was confined to the statutory ceiling under the Central Sales Tax Act. Stainless steel articles such as utensils were distinguished from the sheets from which they were made and continued to fall under the applicable scheduled entries for taxable, and where relevant luxury, goods. Black gram was also maintained at the existing 3% rate. The overall assessment was modified only for the declared-goods items, with the remaining schedule-based treatment preserved.

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Issues: (i) Whether stainless steel sheets are tool alloy steel and therefore declared goods taxable only at 3% under the Central Sales Tax Act; (ii) whether stainless steel articles such as utensils are to be assessed under the schedule applicable to taxable/luxury goods; (iii) whether black gram is assessable at 3%.

Issue (i): Whether stainless steel sheets are tool alloy steel and therefore declared goods taxable only at 3% under the Central Sales Tax Act.

Analysis: The relevant statutory scheme treated iron and steel items as declared goods under section 14(iv) of the Central Sales Tax Act, and section 15 restricted the rate of tax on such goods. The judgment relied on the departmental clarification that stainless steel falls within tool alloy steel and noted that the later amendment expressly recognized tool alloy and special steels. On that basis, stainless steel sheets were treated as covered by the declared goods entry both before and after the amendment.

Conclusion: The issue was decided in favour of the assessee, and stainless steel sheets were held taxable only at 3%.

Issue (ii): Whether stainless steel articles such as utensils are to be assessed under the schedule applicable to taxable/luxury goods.

Analysis: The reasoning distinguished stainless steel sheets from articles manufactured out of such sheets. The judgment maintained the earlier finding that stainless steel articles were not entitled to treatment as declared goods and continued to fall within the relevant scheduled entries for taxable goods and, where applicable, luxury goods.

Conclusion: The issue was decided against the assessee, and stainless steel articles such as utensils were held assessable under the prescribed schedule entries.

Issue (iii): Whether black gram is assessable at 3%.

Analysis: The judgment recorded that the earlier finding on black gram was not open for fresh consideration and sustained the existing rate applied to that turnover.

Conclusion: The issue was decided in favour of the assessee, and black gram was held taxable at 3%.

Final Conclusion: The assessment was modified only to the extent of the items covered by the declared-goods finding, while the remaining item-wise treatment under the relevant schedules was maintained, resulting in a partial success for the assessee.

Ratio Decidendi: Where an item is shown, on the statutory scheme and authoritative clarification, to fall within declared goods as a species of iron and steel, tax cannot be levied beyond the ceiling prescribed by section 15 of the Central Sales Tax Act, 1956.

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