1990 (9) TMI 320

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..... ies 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 exported out of the country. It is not disputed that the rice which is exported out of the country is not liable to .....

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..... ds 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 processing changes the identity of goods. All processings may not change the identity but paddy and rice are two mark .....

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