P.GOVINDA NAIR, T.S.KRISHNAMOORTHY IYER
STATE OF KERALA – Appellant
Versus
MOIDOO – Respondent
1. The only question raised in this Tax Revision Case by the Revenue is whether Dhania (coriander seeds) are'oil-seeds'or not. According to learned counsel for the Revenue coriander seeds are not oil-seeds. The question arose with reference to the assessment to sales tax for the year 1964-65 and the Sales Tax Appellate Tribunal relying on the decision of the Orissa High Court in State of Orissa v. Dinabandhu Sahu & Sons (1969) 24 S.T.C. 233) came to the conclusion that Dhania (coriander seeds) are oil-seeds within the meaning of that expression under S.14 (vi) of the Central Sales Tax Act, 1956, and it was so held that the turnover relating to the sale of coriander seeds are taxable only at a single point. On behalf of the Revenue it is urged that coriander seeds are not oil seeds and so the turnover relating to the sale of those seeds are taxable at all points of sale.
2. S.14 (vi) of the Central Sales Tax Act, 1956 is in these terras:
"14. It is hereby declared that the following goods are of special importance in inter-State trade or commerce:
(vi) oil-seeds, that is to say, seeds yielding nonvolatile oils used for human consumption, or in industry, or in manufacture of
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