RAMAKRISHNAN, J.

These two tax cases were heard together as they raise a common point. We will take up T.C. No. 105 of 1963 first. The assessee is a dealer in cotton and cotton seeds. During the year of assessment 1960-61 it was found that the dealer had with him, at the close of the year, stock of cotton valued at Rs. 2, 27, 250. Cotton in the year in question was an item of declared goods under section 14 of the Central Sales Tax Act, 1956, it being considered to be of special importance in inter-State trade or commerce. The consequence of such a declaration is, as per section 15(a) of the Central Sales Tax Act, that the sales tax law of a State can levy a tax on the sales or purchases of cotton at a rate which shall not exceed two per cent. and the sales tax shall not be levied at more than one stage. There is a further benefit conferred under section 15(b), that where a tax has been levied under the State law on any declared goods and such goods are sold by the assessee thereafter in the course of inter-State trade or commerce, the tax shall be refunded to the assessee subject to certain conditions. We are not now concerned with this last mentioned provision for refu