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6. Learned Counsel for the department placed strong reliance on Tungabhadra Industries Ltd. v. Commercial Taxes Officer (1960) 11 STC 827 wherein the question was whether hydrogenated ground-nut oil is ground nut oil and their Lordships have found it to be so, but that decision cannot apply to the present case because even after hydrogenation, the basic equality of the ground-nut oil continues to be so and it did not get converted into a commercially different commodity. The precise question before the Hon'ble Supreme Court was whether the assessee was entitled to the benefit of the deduction of the purchase price of the kernel or ground-nut, under rule 18(2) of the Madras General Sales Tax (Turnover and Assessment) Rules, 1939, which went to the manufacture of the hydrogenated ground-nut oil from the sale turnover of such oil. While holding that the assessee was so entitled, their Lordships of the Supreme Court referred to the finding of the Tribunal and the High Court to the effect--"that except for its keeping quality without rancidity and case of packing and transport without leakage, hydrogenated oil serves the same purpose as a cooking medium and has identical food value as refined ground-nut oil. There is no use to which the ground-nut oil can be put for which the hydrogenated oil could not be used, nor is there any use to which the hydrogenated oil could be put for which the raw oil could not be used", and added as under: