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31. Learned standing counsel placed reliance upon the following cases: (1) State of Travancore-Cochin v. Shanmugha Vilas Cashew-nut Factory A.I.R. 1953 S.C. 333, wherein it was held that raw cashew-nut becomes commercially different commodity when as a result of processing they are converted into edible kernels, (2) A.H. Abdul S. and Co. v. State of Madras A.I.R. 194 S.C 1729, wherein it was held at page 1733 that raw hides and skins and tanned hides and skins are commercially different commodities as by applying preservative a change is brought in raw hides and skins and a different commercial commodity as a result of processing emerges, (3) Devi Dass Gopal Krishnan v. State of Punjab (19671 20 S.T.C. 430 (S.C.), wherein it was held that by processing, scrap iron loses its identity and becomes rolled steel section and a new marketable commodity is obtained, and (4) Goel Industries (P.) Limited v. Commissioner, Sales Tax, U.P., Lucknow 1971 U.P.T.C. 697, wherein it was held that water and ice were different commodities although chemically composition of both remains the same.