Bullion classification: embossed gold coins are manufactured gold articles, not unwrought bullion, for tax purposes.

Gold coins embossed with Goddess Lakshmi were held not to be bullion under the common parlance test, because bullion means gold in the mass, such as raw gold, bars or ingots, and not finished or manufactured goods. Once gold bars are converted into coins and given embossing or engraving, they undergo a manufacturing process and acquire value addition, taking them out of the bullion category. The coins were therefore classified as manufactured gold articles and taxed at the higher rate. The Tribunal's view treating them as bullion was incorrect, and the assessment classifying them as gold articles was restored.

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Issues: Whether gold coins embossed with Goddess Lakshmi, sold with making charges and value addition, retain the character of bullion and are taxable at the concessional rate applicable to bullion, or whether they constitute manufactured gold articles taxable at the higher rate.

Analysis: The classification turned on the ordinary and commercial meaning of bullion. Applying the common parlance test, bullion denotes gold in the mass, such as raw gold, bars or ingots, and not finished or manufactured products. Once gold bars or ingots are converted into coins and given embossing or engraving, they undergo a manufacturing process and acquire value addition, taking them out of the category of bullion. Gold coins with engraved images are therefore distinct commercial goods and cannot be treated on par with unwrought gold, especially where the trade itself reflects a higher value than bullion rate by including making charges and wastage.

Conclusion: Gold coins embossed with Goddess Lakshmi are not bullion in uncoined or unwrought form and are liable to be taxed as gold articles at the higher rate.

Final Conclusion: The Tribunal's classification of the impugned gold coins as bullion was incorrect, and the assessment treating them as taxable gold articles was restored.

Ratio Decidendi: For sales tax classification, bullion means gold in the mass or unwrought form; once gold is manufactured into coins or similar finished items with embossing or engraving, it ceases to be bullion and falls to be classified as a manufactured gold article.

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