Judgment

B. P. JEEVAN REDDY, J. - A difference of opinion has arisen among the High Courts in the country over the question whether the expression wheat in S. 14(i)(iii) of Central Sales Tax Act (Act) includes flour, maida and suji. Karnataka and Patna High Courts have held that it does so include, while Andhra Pradesh, Rajasthan and - we are told - Madras High Courts have taken a contrary view.

2. S. 14 occurs in Chapter IV which carries the heading "Goods of special importance in Inter-State Trade or Commerce." S. 14 declares certain goods to be of special importance in inter-State trade and commerce, hereinafter referred to as "declared goods". The first clause, introduced in 1976** is cereals. As many as ten commodities are mentioned under Cl. (i) which reads as follows :

"Section 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 or commerce:-

[(i) Cereals, that is to say,-

(i) Paddy (Oryza Sativa L.);

(ii) Rice (Oryza Sativa L.):

(iii) Wheat (Triticum Vulgare, T. compactum, T. sphaerococcum, T. durum, T. aestivum L., T. dicoccum);

(iv) Jowar or milo (Sorghum vulgare P