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PETITIONER: TVL K.A.K. ANWAR & CO. ETC.

       Vs.

RESPONDENT: STATE OF TAMIL NADU

DATE OF JUDGMENT:       27/11/1997

BENCH: S.C. SEN, B.N. KIRPAL, K.T. THOMAS

ACT:

HEADNOTE:

JUDGMENT:                  THE 27TH OF NOVEMBER, 1997 Present:                 Hon’ble Mr. Justice S.C.Sen                 Hon’ble Mr.Justice B.N.Kirpal                 Hon’ble Mr. Justice K.T.Thomas K. Parasaran,  H.N. Salve  and S. Sivasubramaniam, Sr.Advs., A.T.M.Sampath, V.Balaji,  K.J. Chandran,  Nikhil Sakhandand, K.K. Mani,  R. Ayyam  Perumal, V.G. Pragasam, K. Swami, P.R. Tiwari, A.  Raghunath, A.  Mariarputham,  V.  Krishnamurthy, Advs. with them for the appearing parties.                       J U D G M E N T The following Judgment of the Court was delivered:                             WITH     Civil Appeal Nos. 4747-48, 4749-50, 4751-52 of 1993              6660 of 1995, 1453 and 855 of 1994 KIRPAL, J.      Leave granted in SLP (c) Nos. 5384-85 of 1984.      The common  question which  arises in  these appeals is whether the  turn-over in  respect of  hides and skins which has once  been subjected to tax under the Tamil Nadu General Sales Tax  Act, on  its purchase  at the raw stage, could be taxed again  on inter-state sales as tanned or dressed hides and skins.      According to the appellants they purchase raw hides and skins and  after dressing  they are  sold in  the course  of inter-state trade.  The contention of the dealers before the assessing authority  was that  hides and skins, whether in a raw or  dressed form,  are declared  goods under  Section 14 (iii) of  the Central Sales Tax Act and they are regarded by the sald Act as a single commodity. This being so Section 15 of the  Central Sales  Tax Act provides that the goods which have suffered  tax once cannot be taxed again at the time of inter-state sale.  As the tax had been levied at the time of purchase of  raw hides and skins, therefore, there should be no levy  of tax on their inter-state sale after the said raw hides and skin had been dressed.      The assessing  authority, in  all these  cases, did not accept the  said contention  as the  authorities were of the opinion that raw hides and skins were a commodity which were different from  dressed hides  and skins and, therefore, the

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restrictions contemplated by Section 15 of the Central Sales Tax Act was not applicable.      The decision  of the assessing authority was challenged by  some  of  the  appellants  by  taking  recourse  to  the provisions under  the Act and after an adverse decision from the Tribunal,  revision petitions  are filed before the High Court at  Madras. Some  of the  other  appellants  chose  to challenge the decision of the sales tax authority as well as the constitutional  validity of  Section 3 of the Tamil Nadu General Sales  Tax (3rd  Amendment) Act,  1987  substituting item no.  7 and  the relevant  entries thereto  in the  IInd filing writ  petitions before  the High Court of Madras. The High Court,  by different  decisions, came to the conclusion that  raw   hides  and  skins  was  a  commodity  which  was commercially different  from dressed  hides and  skins  both under the  State Act as well as the Central Act and that the State had  the legislative competence to tax the inter-state sale of  dressed hides  and skins  even though  tax had been paid on  the purchase  of raw  hides and  skins. The further finding of the High Court was that there was no merit in the challenge to  the legality  of the  entries which  had  been substituted in  the IInd  Schedule by  the Amending  Act  of 1987.      The controversy  in  these  appeals  relates  to  three periods, namely,  for the  period prior to 23rd March, 1987; for the period 23rd March, 1987 to 4th September, 1991, when amendment was  made  to  item  no.7  to  the  IInd  Schedule pursuant to  the aforesaid  Amending Act  and for the period subsequent to 4th September, 1991 when the said schedule was again amended,  as a  result of which the original entry got restored.      In order  to appreciate  the rival  contentions  it  is necessary to  refer to the statutory provisions. Sections 14 and 15  of the  Central Sales Tax Act, in so far as they are relevant for the purpose of these cases, are as under:      "14. Certain goods to be of special      importance in  Inter state trade or      commerce:-      It  is  hereby  declared  that  the      following  goods   are  of  special      importance in  inter state trade or      commerce:-      ........      (iii) hides and skins, whether in a      raw or dressed state."      15. Restrictions  and conditions in      regard to  tax on  sale or purchase      of declared goods within a State:-      Every sales  tax  law  of  a  State      shall, in  so far  as it imposes or      authorises the  imposition of a tax      on the sale or purchase of declared      goods, be  subject to the following      restrictions    and     conditions,      namely:-      (a) the  tax payable  under the law      in respect  of any sale or purchase      of  such  goods  inside  the  State      shall not  exceed four  per cent of      the sale or purchase price thereof,      and such tax shall not be levied at      more than one stage;      (b) Where  a tax  has  been  levied      under that  law in  respect of  the      sale or  purchase inside  the State

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    or  any  declared  goods  and  such      goods are  sold in  the  course  of      inter state  trade or commerce, and      tax has been paid under this Act in      respect of  the sale  of such goods      in the  course of inter state trade      or commerce,  the tax  levied under      such law shall be reimbursed to the      person  making  such  sale  in  the      course  of  inter  state  trade  or      commerce in such manner and subject      to  such   conditions  as   may  be      provided in  any law  in  force  in      that State.      ............      (Provision  extracted  is  the  one      which was in force in 1987)      After the promulgation of the Central Sales Tax Act the State Legislature introduced IInd Scheduled to the State Act providing for  the rates  as well  as the  points of levy in respect of  declared goods.  This was  done in  view of  the provisions of Sections 14 and 15 of the Central Act.      "Item No.7  of the  Second Schedule  in so  far  as  it related to  the levy  of sales tax on hides and skins, as it was originally  enacted and  in force upto 22.3.1987 read as hereunder: ---------------------------------------------------------- Sl. No.    Description    Point    Rate of    Effective             of goods      of levy  tax per      from                                      cent (1)           (2)           (3)      (4)         (5) ----------------------------------------------------------- 7.             ORIGINAL & PRESENT ENTRY (a)            Raw hides   At the point 2      1.4.1959                and skins   of last purchase                            in the State. 3    18.6.1967 (b)            Dressed     At the point  1     1.4.1959                hides and   of first sale 1-1/2 18.6.1967               skins (which in the State               were not               subjected to               tax under                   2     21.2.1978               this Act as               raw hides and                skins). Note: Rate of  tax increased  on item 7 (a) from 2% to 3% by Act 5 of 1967 w.e.f. 18.6.1967. Rate of tax increased on item 7 (b) from 1% to 1-1/2% w.e.f. 18.6.1967 by  Act 5  of 1967  and from  1-1/2% to  2% w.e.f. 21.2.1978 by Act 22 of 1978" After and  by virtue  of the  impugned Amendment  Act 31  of 1987, which was proceeded by G.O.P. No. 291 dated 20.3.1987, item 7  of the  Second Schedule  and  the  relevant  entries thereto read as hereunder: "7(a)         Raw hides     At the point  2               and skins.    of last                             purchase in                             the State. (b)           Dressed       At the point               hides and     of first sale               skins.        in the State. 2 ------------------------------------------------------------ With effect  from 6th  September, 1991 item no.7 of the IInd Schedule was once again substituted and after such amendment

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the item read as under:- "7(a)        Raw hides      At the point              and skins      of last                             purchase in                             the State     4 (b)         Dressed hides   At the point             and skins       of first sale             (which were     in the State. 4             not subjected             to tax under             this Act as             raw hides and             skins).      The main thrust of the arguments of the learned counsel for the  appellants was two fold. It was explained that with a view  to preserve  the raw  hides and skins they are first ‘cured’ by either wet salting, dry salting or drying. In the ‘cured state’  the raw  materials can  be  preserved  for  a temporary period.  In the next stage the hides and skins are ‘picked’ and  thereafter they are tanned in which state they can be preserved almost indefinitely. These tanned hides and skins are processed further to yield dressed hides and skins which are  then ready  for use.  It was  submitted that  raw hides and skins and dressed hides and skins, irrespective of their state,  are the same commodities. After ‘raw hides and skins’ are  purchased they  are then  dressed which  has the effect of  preserving them.  They do  not undergo any change and, therefore, ‘raw hides and skins’ and ‘dressed hides and skins’  cannot   be  considered   as  commercially  separate commodities, the  difference being  only in form. This being so, it  was contended,  hide and  skins can be taxed at only one stage  in the  State with  the result  that if they have been subjected  to tax at the raw state under the local Act, then section  15 of the Central Sales Tax Act would have the effect of  preventing tax  being levied on dressed hides and skins.      In the alternative, it was contended that even assuming that ‘raw  hides and  skins’ and  ‘dressed hides  and skins’ could be  considered to be commercially distinct commodities under Section  14(III), even  then Section  14(III)  of  the Central Sales  Tax Act  regards hides  and skins as a single commodity and  they cannot  be taxed  twice over  in any one State. Elaborating  this contention,  it was  submitted that Section 15  of the Central Sales Tax Act provides that every sales tax  law of  a State  shall, insofar  as it imposes or authorises the  imposition of tax on the sale or purchase of declared goods,  imposes two  restrictions, namely,  the tax payable of declared goods, imposes two restrictions, namely, the tax  payable in respect of "such goods" cannot exceed 4% and; secondly  it cannot  be levied  at more than one stage. The expression  "such goods" occurring in Section 15, clause (a), it was submitted, meant "declared goods" referred to in Section 14 which, in the present case, is hides and skins. A necessary corollary  of this  was that hides and skins could be taxed  only once in a State and once hides and skins have been taxed  in a  State, in whichever form it may have been, the same  cannot be  taxed again. Therefore if the State law regarded them  as different  goods enabling the State to tax them twice,  then to  that extent the relevant provisions of the State  law, being  in conflict  with Section  15 of  the Central Sales Tax Act, would be ultra vires.      On behalf of the appellants, strong reliance was placed on the decision of this Court in the cases of State of Tamil Nadu Vs.  Mahi Traders  and Ors. Etc. etc., (1989 (1) S.C.R. 445), State  of Punjab  and Ors. Vs. M/s. Chandu Lal Kishori

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Lal and  Ors. Etc.  [(1969)  3  SCR  849],  Telangana  Steel Industries and  Ors. Vs.  State of A.P. and Ors. (1994 Supp. (2) SCC  259) and State of Tamil Nadu Vs. Pyare Lal Malhotra Etc. [(1976)  3 S.C.R.  168]. In  Chandu Lal’s case (supra), the leader had paid purchase tax on the purchase of unginned cotton and, after ginning the cotton and removing the seeds, it had  sold the  ginned cotton  to  customers  outside  the State.  In  respect  of  the  cotton  seed  sold  by  it  to registered dealers,  a deduction  had been  claimed from the purchase turnover but the same was not allowed on the ground that the  goods sold, namely cotton seed, were not the goods in respect of which purchase tax had been levied inasmuch as unginned cotton  underwent a  manufacturing process  and the goods produced were different from those purchased. Allowing the appeal  of the  State of Punjab, a three Judges Bench of this Court  observed at  page 853  that "declared  goods" in Section  14   of  the   Central  Sales  Tax  Act,  1956  are individually specified  under separate items. "Cotton ginned or unginned" is treated as a single commodity under one item of declared  goods’. Reliance was placed on this observation and it  was contended  that because  the  entry  in  Section 14(III) reads  as hides  and skins, raw or dressed, it would mean that  raw hides  and skins  and dressed hides and skins are treated as a single commodity.      In the case of Mahi Traders (supra), the question which arose was  whether leather  splits and coloured leather were hides and  skins which  fall in  the category  of  "declared goods" as set out in Section 14 of the Central Sales Tax Act and, therefore,  entitled to  the concession available under Section 15  of the Act, namely, the benefits of single point taxation and  of a smaller rate of tax. This Court held that leather splits  were nothing  but cut  pieces of  hides  and skins and  would, therefore,  fall within Section 14(III) of the  Central  Sales  Tax  Act.  Dealing  with  the  question relating to  coloured leather,  the  Court  dealt  with  the process in  which the  raw hides and skins undergo till they are tanned and observed as follows:      "Structurally, hides and skins have      a thick middle layer called corium,      which is  converted to  leather  by      tanning. The operations involved in      leather  manufacture  however  fall      into  three   groups.   Pre-tanning      operations include soaking, liming,      deliming, bating  and  picking  and      post   tanning    operations    are      splitting       and        shaving,      neutralising,  bleaching,   dyeing,      fat-liquoring and stuffing, setting      out, samming,  drying, staking  and      finishing. These  operations  bring      about  chemical   changes  in   the      leather substance and influence the      physical  characteristics   of  the      leather, and different varieties of      commercial leather  are obtained by      suitably       adjusting        the      manufacturing   operations.   These      processes need  not be gone into in      detail but the passages relied upon      clearly show  that hides  and skins      are termed  ‘leather’ even  as soon      as the  process of  tanning is over      and    the    danger    of    their      putrefaction is  put an end to. The

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    entry  in  the  CST  Act,  however,      includes within its scope hides and      skins  until  they  are  ‘dressed’.      This, as  we have  seen, represents      the stage  when  they  undergo  the      process of  finishing and  assume a      form in  which they  can be readily      utilised for manufacture of various      commercial articles.  In this view,      it is hardly material that coloured      leather may be a form of leather or      may even  be said  to  represent  a      different commercial commodity. The      statutory  entry  is  comprehensive      enough  to   include  the  products      emerging from hides and skins until      the   process    of   dressing   or      finishing   is   done".   (emphasis      added) This Court  then concluded  that splits and coloured leather continued  to  be  hides  and  skins  entitled  for  special treatment under the Central Sales Tax Act.      In Telangana  Steel Industries  and Others Vs. State of A.P. and  others (1994  Supp (2)  SCC 259,  the question was whether iron  wires were separate commercial goods from wire rods from which they were produced. Without deciding whether both the  goods were  one commercial  commodities or not and after referring  to the  decision of  State of Tamil Nadu Vs Pyare Lal  Malhotra Etc.,  [(1976) 3  SCR 168] and Rajasthan Roller  Flour  Mills  Association  and  Anr.  Vs.  State  of Rajasthan and Ors., (1994 Supp (1) SCC 413), this Court held that as  both the  rods and  wires form part of one sub item viz., (iv) (xv), they could not be taken as separate taxable commodity and  if wire  rod which  had been purchased by the dealers had  already been subjected to sales tax, then wires which are drawn from the said rods could not be taxed again. In arriving  at this  conclusion, it  was observed that when the sub-item  spoke of  wires  "rolled,  drawn,  galvanized, aluminized, tinned  or coated...."  it showed  that even  if they were  separate commercial  commodities, the Legislature nevertheless did  not want  wires to be taken as a commodity different from rods for the purpose of permitting imposition of sales  tax once  again on wires, despite rods having been subjected to sales tax.      Even though the aforesaid decisions seem to support the contentions urged  on behalf of the appellants, we find that the two  questions involved  in these cases, namely, whether dressed hides  and skins  and raw hides and tanned skins are different commodities and, secondly, whether Section 14(iii) of the  Central Sales  Tax Act  regards them  as the  single commodity, appear  to have  been decided  differently  by  a Constitution Bench  of this Court in Hajee Abdul Shakoor and Company  Vs.  State  of  Madras  [1964  (8)  SCR  217].  The appellant therein  had contended  that tanned  and  untanned hides and  skins did  not form  different  commodities  and, therefore, tax could not be levied on the sales of hides and skins in the raw condition when no tax is levied on the sale of hides  and skins  in the  tanned condition.  On the other hand the  State had  contended that  they were two different commodities and constituted two separate commodities for the purpose of  taxation. The  Court at  page 227  observed that "hides and  skins in  the untanned condition are undoubtedly different as  articles of  merchandise than tanned hides and skins." If  then dealt  with the contention that tanning was only a  preservative process  which makes  no change  in the

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nature of  the article  itself, a  submission which has also been raised  in the present case on behalf of the appellant. The Court,  however, did  not accept  this submission and in this connection  it approved  the observations in Government of Andhra  Pradesh Vs.  M.A. Abdul  Bari and  Company (9 STC 231) to the effect that tanning of raw hides and skins was a manufacturing process  as a result of which the product that emerges is  different from the raw material as after tanning the hides  and skins  become a  different commodity and then concluded at page 228 that "it is, therefore, not correct to say that  the process  of tanning  brings about no change in the raw  hides and  skins and  that therefore  both types of hides and  skins form  one commodity." The appellant therein had also  referred to  the  decision  in  Abdul  Subban  and Company Vs. State of Madras (11 STC 173) where the following observations had been made at page 228:      "Section 14(3) of the Central Sales      Tax Act, 1956 (Act 74 of 1958) also      treats  hides   and  skin   whether      dressed  or   raw,  as   a   single      commodity... Since  skins tanned or      untanned, constitute only one class      of goods and the sale of that class      of goods  can be  taxed only  at  a      single point,  obviously there  can      be no  tax  on  a  sale  of  tanned      goods, if tax has already been paid      on  an   earlier  transaction  when      those skins were untanned." The aforesaid  conclusion in  Abdul Subban’s  case  was  not accepted by  this Court and it was observed at page 228 that "no reason is given why the two kinds of hides and skins are treated as  a single  commodity."  Again  at  page  229  the finding of  the Court was that "we, therefore, hold that raw hides and skins dressed hides and skins constitute different commodities of  merchandise  and  they  could  therefore  be treated as different goods for the purposes of the Act."      From the aforesaid observations it clearly follows that the Constitution  Bench had,  in no uncertain terms, come to the conclusion  that raw  hides and  skins and dressed hides and skins  were not  one and  the same commodity. Therefore, the first  contention raised  in the  present  case  by  the learned  counsel   for  the  appellant  cannot  be  accepted notwithstanding  the  reliance  by  them  on  the  aforesaid decision in the case of Telanganna Steel Industries case. It may here  be noted  that in  none of these decisions was the attention of  the Learned  Judges  drawn  to  the  aforesaid observations of  the Constitution  Bench in  Abdul Shakoor’s case.      The  other  submission  that  Section  14(iii)  of  the Central Sales  Tax Act,  in any  case, treats  raw hides and skins and  dressed hides  and skins  as  one  and  the  same commodity, because it is included in the same sub-heading in Section 14 also stands concluded by Abdul Shakoor’s case. As already noted herein above, this Court specifically referred to those  observations in  Abdul Subban’s case (supra) which had interpreted  Section 14  (iii) of  the Central Sales Tax Act to mean that hides and skins whether dressed or raw were single commodity  and this  observation was disapproved when at page 228 this Court observed in Abdul Shakoor’s case that "no reason is given why the two kinds of hides and skins are treated as a single commodity". The Court was called upon to refer to  the provisions  of Section  5 Clause  (vi) of  the Madras General Sales Tax Act, 1959 which related to the levy of tax  on the  sale of  hides and  skins and  which read as

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follows:      "Subject to  such restrictions  and      conditions as  may  be  prescribed,      including conditions as to licences      and licence fees.....      (vi) The  sale of  hides and skins,      whether tanned or untanned shall be      liable to tax under section 3, sub-      section (1)  only  at  such  single      point  in   series  of   sales   by      successive  dealers   as   may   be      prescribed. (emphasis added) This provision  was replaced  by Section  5A (4) which is as under:      "The  sale   of  hides  and  skins,      whether in  a raw or dressed state,      shall be liable to tax only at such      single point in the series of sales      by successive  dealers  as  may  be      prescribed but  at the  rate of two      percent on  the  turnover  at  that      point." (emphasis added) The Court  while interpreting the said provisions then held, as under:      The real  question is whether these      provisions that raw hides and skins      and dressed  or  tanned  hides  and      skins as one class of goods for the      purpose  of   taxation  or  as  two      different classes of goods. If they      threat them  as one class of goods,      the contention at the time of their      sale in  a raw  condition meets the      requirements of  law as  hides  and      kins  could  be  taxed  only  at  a      single point.  If  the  dressed  or      tanned  hides  and  skins  are  not      taxed at  the time  of  their  sale      that does  not offend  against  the      statutory provisions.  No  question      of discrimination  arises as a sale      of raw  hides and skins of whatever      origin, i.e.,  whether produced  in      the  State  or  imported  into  the      State would  be equally  liable  to      the levy of tax.      If the  statute treats  both  these      kinds  of   hides  and   skins   as      different      commodities      the      provisions of  sub-rule (1) of r.16      providing for  the levy  of tax  on      raw hides  and skins  at a  certain      point even  in the  absence of  any      provision  for   the  taxation   of      dressed hides  and skins  cannot be      said  to   be  discriminatory   and      invalid. The  articles to  be taxed      were   not   the   same   and   the      legislature      could      provide      differently about their taxation.                  (emphasis added) The language  of Section  14 (iii)  of the Central Sales Tax Act  is  similarly  worded  as  the  language  of  aforesaid Sections 5  (vi) and 5A of the Madras General Sales Tax Act. It is  while interpreting this that it was held that raw and

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dressed hides  and skins were different articles and that is why the  legislature could  provide differently  about their taxation. The  fact that  both the  articles  are  mentioned under the  same heading  is also of no material consequence. After referring  to Raghbir  Chand Som  Chand Vs. Excise and Taxation Officer  (11 STC  149) wherein  it  was  held  that ginned and  unginned cotton  constituted one commodity inter alia for  the reason  that ginned  and un-ginned cotton were under  the   same  head  and  thereby  indicating  that  the legislature looked  upon ginned  and un-ginned cotton as one and the  same thing,  it was held in Abdul Shakoor’s case at page 229  that "The fact that certain articles are mentioned under the same heading in a statute or the Constitution does not  mean  that  they  all  constitute  one  commodity.  The inclusion of  several articles under the same heading may be for a reason other than that the articles constitute one and the same  thing." This means that merely being put under one head would  not make two different commodities a single item for purposes of taxation.      When dressed  hides and  skins are different goods from raw hides and skins, we do not find anything in the language of Section 14 of the Central Sales Tax Act which can lead us to the  conclusion that these two different commodities were to be  regarded as  constituting a  single commodity for the purpose of taxation. Sections 14 and 15 of the Central Sales Tax Act have to be read together as they constitute a scheme relating to  taxation of  goods  of  special  importance  in inter-state trade  or commerce.  While Section 14 enumerates the items  which are  regarded as  being  goods  of  special importance in  inter-state trade  or commerce, it is Section 15 which imposes the restriction and conditions in regard to tax on  sale or  purchase of  declared goods within a State. Section 14, in other words, is not a taxing provision but it merely  classified  different  commodities  under  the  same species under  one entry.  Merely because different goods or commodities are  listed together  in the same sub-heading or sub-item in Section 14 cannot mean that they are regarded as one and  the same  item.  Whenever  the  legislature  wanted different goods placed in the same entry to be regarded as a single commodity  it expressly provided for the same. By Act 103 of  1976 sub-sections  (c)  and  (d)  were  inserted  in Section  15   of  the   Central  Sales  Tax  Act.  With  the introduction of Section 115 (d) "each of the pulses referred to  in  Clause  (vi-a)  of  Section  14,  whether  whole  or separated and,  whether with  or without  husk, were  to  be treated as a single commodity of the purposes of levy of tax under that  law." If  the intention  of the  legislature had been that  the various  commodities mentioned  in  the  same clauses in  Section 14  were to  be  regarded  as  a  single commodity it  would have  specifically provided as such. The legislature, however, chose to single out different types of pulses  only   to  be   regarded  as   a  single  commodity. Notwithstanding the  fact that  the raw  hides and skins had been held  by this  Court in Abdul Shakoor’s case (supra) as being distinct  from dressed hides and skins the legislature did not  think it  appropriate to insert a clause similar to Section 15  (d) which  may have  had the effect of regarding raw hides  and skins  and dressed  hides and  skins as being treated as  a single  commodity for  the purposes of levy of tax.      The words "hides and skins, whether in a raw or dressed state" in  Section 14(iii)  of the  Central  Sales  Tax  Act clearly seem  to indicate  that the  legislature  recognised that raw  hides and skins was an item different from dressed hides and  skins. As has already been noticed hereinabove it

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is  after   undergoing  a  manufacturing  process  involving various stages  that raw  hides and  skins  becomes  dressed hides and  skins. As observed in the State of Tamil Nadu Vs. Pyare Lal  Malhotra Etc. (1976 (3) SCR 168) at page 173 that "sales tax  law  is  intended  to  tax  sales  of  different commercial commodities  and not to tax the production of the manufacture of  particular substances  out  of  which  these commodities  may   have  been  made.  As  soon  as  separate commercial commodities  emerge or  come into existence, they become separately goods, without change of their identity as such goods,  are merely  subjected  to  some  processing  or finishing or  are merely  jointed together,  they may remain commercially the  same goods which cannot be taxed again, in a series  sales, so  long as  they retain  their identity as goods of  a particular  type. In  the present  case  dressed hides and  skins is  a separate  commercial commodity  which emerges after  raw hides  and skins  has been  subjected  to manufacturing process  and, therefore, Section 14(iii) deals with two  different types  of goods which unlike the case of pulses referred to in Section 15 (d), is not regarded by the Act as one and the same commodity.      Having come  to the conclusion that raw hides and skins and dressed hides and skins are two types of commodities, it must flow  therefrom that  when the appellants purchased raw hiides and  skins on  payment of tax they would be liable to pay sales tax in respect of dressed hides and skins and such levy will  not fall  foul of Section 15 as the two goods are different taxable commodities. In other words the same goods would not  have been  taxed more  than once. In our opinion, therefore  the  High  Court  was  right  in  coming  to  the conclusion  which   it  did,  namely,  that  the  sales  tax authorities could  levy sales  tax on  the sale  of  dressed hides and  skins and that the provisions of Section 3 of the Tamil Nadu  General Sales  Tax (3rd Amendment) Act, 1987 are not ultra vires.      The appeals  are accordingly dismissed with no order as to costs.