1990 (9) TMI 320

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....titions the question involved is whether paddy and rice are one and the same commodity or two different commodities for the purposes of State and Central Sales Tax Act. Our answer is that they are two different commodities. The petitioners are the last purchasers of paddy. They husk paddy and produce rice. The rice produced by them is sold either within the State or in inter-State sale or expor....

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....addy and rice are two different commodities in the ordinary parlance and on dehusking change in the commodity of goods is brought out and that if paddy and rice are taxed it cannot be said that there is double taxation. Similarly, in Ben Gorm Nilgiri Plantations Co. v. Sales Tax Officer [1964] 15 STC 753 and Sterling Foods v. State of Karnataka [1986] 63 STC 239 the highest Court has held that ....