Paddy And Rice

Paddy and rice, although rice is produced out of paddy, it is not true to say that paddy continued to be paddy even after dehusking. Rice and paddy are two different things in ordinary parlance and therefore, when paddy is dehusked and rice pro-duced, there is a change in the identity of the goods. Inclusion of paddy and rice in schedule 'C' would not amount to double taxation, Babu Ram Jagdish Kumar and Co. v. State of Punjab, AIR 1979 SC 1475 (1485): (1979) 3 SCC 616: (1979) 3 SCR 952.