JUDGMENT BILAL NAZKI, J. The petitioners in all the writ petitions are carrying on business of excavating and selling granite. For different years they were assessed both under the provisions of the Andhra Pradesh General Sales Tax Act, 1957 (for short, "the APGST Act") and the Central Sales Tax Act, 1956 (for short, "the CST Act") by the first respondent on different dates. The turnover mentioned by the petitioners represent the sales of granite to dealers in the State and others in form "H" issued under the provisions of the CST Act and the Rules made thereunder. Assessment was made. Thereafter the Deputy Commissioner suo motu issued the notices reopening the assessments for disallowing exemption allowed by the first respondent on the turnover and called the petitioners to file their objections. The petitioners filled their objections and the Deputy Commissioner revised the order. In all the writ petitions except W.P. No. 27830 of 1996 the revisional orders were challenged by way of appeals. While the appeals were pending stay was sought. Stay applications were dismissed by the appellate court; revisions were filed before the Joint Commissioner against the said orders and they were also dismissed. These orders have been challenged in these writ petitions. In one case being W.P. No. 22168 of 1996 no order was passed by the appellate authority therefore writ petition was filed with the prayer that the appellate authority should be directed to dispose of the appeal and grant stay till the disposal of the appeal. In W.P. No. 27830 of 1996 no appeal was filed and the order passed by the Deputy Commissioner has been challenged directly. The only argument advanced at the Bar by the learned counsel for the petitioners was that, rough granite was sold to 100 per cent export oriented units and polishing would not make it a different commodity and the rough and polished granite were the same commodity therefore they were exempt from the sales tax. The case of the petitioners is that granite blocks when converted into polished stones do not create a new product therefore the authority concerned was not right in passing the impugned orders. Several judgments were pressed into service but before going to those judgments it will be profitable to note the admitted facts with regard to the controversy. The case of the petitioners is that granite blocks when converted into polished stones do not create a new product therefore the authority concerned was not right in passing the impugned orders. Several judgments were pressed into service but before going to those judgments it will be profitable to note the admitted facts with regard to the controversy. The order of first assessment with regard to the petitioner in No. 27830 of 1996 noted : "...... on verification of sale invoices, it is noticed that the dealers have sold rough granite stones to the registered dealers at Tada for Rs. 20,00,250 (Bill Nos. 2/30-08-92, 3/30-11-92, 4/30-11-92 and 8/92-93 dated March 30, 1993) which are said to be meant for export purpose. This turnover was proposed to be deducted under the CST Act. In all other cases the assesses had sold rough granite stones to the registered dealers in this State, and the assesses are not the last sellers in the State." During the departmental enquiries it was revealed that they purchased rough granite and polished the same, cut them in sizes and then sold them to the foreign countries. From the observation of the assessing officer and from the enquiries it becomes clear that the petitioners had sold rough granite which was polished and cut into different sizes and then exported. In the light of this factual position it will have to be seen whether the petitioners were entitled to exemption under section 5(3) of the CST Act or they were exempt from tax under the APGST Act. It will be profitable to note that there are two different entries in the Schedule I of the APGST Act dealing with the subject. Entry 32 lays down : 32. Bricks, tiles, cement flooring stones At the point of last and granite stones including boulders sale in the State and chips. Entry 92 reads : 92. Mosaic tiles and chips, polished At the point of first granite stones, ceramic and sale in the State. glazed floor and wall tiles and joining powder and situ mixtures. So, these entries clearly shows that polished granite stones are different commodity than granite stones; whereas granite stones have to be taxed at the point of last sale in the State the polished granite stones have to be taxed at the point of the first sale in the State. glazed floor and wall tiles and joining powder and situ mixtures. So, these entries clearly shows that polished granite stones are different commodity than granite stones; whereas granite stones have to be taxed at the point of last sale in the State the polished granite stones have to be taxed at the point of the first sale in the State. The evidence conclusively shows that what was sold was granite stones at the last point, when they were sold in the form of granite stones they were sold by the petitioners and when they were exported by the export units they were exported as polished stones. A distinction was sought to be drawn by the petitioners' counsel that entry 92 is meant for mosaic tiles and it has to be read in the context of mosaic tiles and chips and the "polished granite stone" as occurring in entry 92 would have to be given a meaning while connecting it to the mosaic tiles and chips. This distinction is far-fetched. Many authorities have been cited to show that rough granite stone and the polished granite stone are one and the same commodity. The authorities quoted are Commissioner of Sales Tax, U.P. v. Lal Kunwa Stone Crusher (P) Ltd. [2000] 118 STC 287 (SC), Poonam Stone Processing Industries v. Deputy Commissioner of Commercial Taxes (Admn.), Gulbarga [1994] 94 STC 183 (Kar) and State of Tamil Nadu v. O. P. Aliyar [1992] 87 STC 339 (Mad.). We do not want to deal with the judgments in detail in view of the fact that entries 32 and 92 are clear and unambiguous. The Legislature has thought it fit to distinguish the rough granite stone from the polished granite stone. The cases which have been cited are those cases where there was no entry with respect to one of the commodities in question. For instance in the latest case reported in Commissioner of Sales Tax, U.P. v. Lal Kunwa Stone Crusher (P) Ltd. [2000] 118 STC 287, the Supreme Court dealt with a case of stone chips. The dealer had purchased stone boulders and crushed them into stone chips. The Supreme Court was interpreting entry 40 of the concerned Act. The entry read, "Ramraj, geru, surkhi, sand, lime, bajri, marble-chips, moram, gitti, kankar, stone ballast, stone and articles of stone except of glazed stone". In para 4 of the Supreme Court laid down : "4. The dealer had purchased stone boulders and crushed them into stone chips. The Supreme Court was interpreting entry 40 of the concerned Act. The entry read, "Ramraj, geru, surkhi, sand, lime, bajri, marble-chips, moram, gitti, kankar, stone ballast, stone and articles of stone except of glazed stone". In para 4 of the Supreme Court laid down : "4. Here in the present case, the goods that are brought into taxation are enumerated in entry 40 of the notification dated September 7, 1981 to which we have adverted to earlier. Each one of the items enumerates various goods, which could be brought to tax. The purpose of sales tax is to levy tax on sale of goods of each variety and not the sale of the substance out of which they may have been made. As soon as separate commercial commodities emerge or come into existence, they become separately taxable goods for purposes of sales tax. Where commercial goods, without change of their identity as such goods, are merely subjected to some processing or finishing, they may remain commercially the same goods which cannot be taxed again, in a series of sales, so long as they retain their identity as goods of a particular type. ....." Since there was one entry only with respect to the "stones" and "stone ballast" therefore the Supreme Court found that by grinding the stone boulders into chips the commodity remained the same for the purpose of sales tax, but in the present case there are two different entries available for raw granite stone and polished granite stone and what the petitioners sold was the raw granite stone and it was exported by a export unit after polishing and cutting. The export unit did not sell the rough granite as they purchased but they sold it after polishing and cutting. The present case is almost similar to the case in K.A.K. Anwar & Co. v. State of Tamil Nadu [1998] 108 STC 258 (SC); (1998) 26 APSTJ 64. This was a matter of raw hides and skins and dressed hides and skins. The entries that were subject-matter of consideration before the Supreme Court were 7(a) and 7(b). The present case is almost similar to the case in K.A.K. Anwar & Co. v. State of Tamil Nadu [1998] 108 STC 258 (SC); (1998) 26 APSTJ 64. This was a matter of raw hides and skins and dressed hides and skins. The entries that were subject-matter of consideration before the Supreme Court were 7(a) and 7(b). They read as under : "7(a) Raw hides and skins At the point of last purchase in the State 7(b) Dressed hides and skins (which were At the point of not subjected to tax under this Act first sale in the as raw hides and skins)" State. The Supreme Court after considering all the judgments on the subject came to the conclusion that : "The words 'hides and skins, whether in a raw or dressed state' in section 14(iii) of the Central Sales Tax Act clearly seem to indicate that the Legislature recognised that raw hides and skins was an item different from dressed hides and skins. As has already been noticed hereinabove it is after undergoing a manufacturing process involving various stages that raw hides and skins become dressed hides and skins. As observed in the State of Tamil Nadu v. Pyare Lal Malhotra [1976] 37 STC 319 (SC) at page 325; [1976] 3 SCR 168 at page 173 that sales tax law is intended to tax sales of different commercial commodities and not to tax the production or the manufacture of particular substances out of which these commodities may have been made. As soon as separate commercial commodities emerge or come into existence, they become separately taxable goods or entities for purposes of sales tax. Where commercial goods, without change of their identity as such goods, are merely subjected to some processing or finishing or are merely joined together, they may remain commercially the same goods which cannot be taxed again, in a series of sales, so long as they retain their identity as goods of a particular type. Where commercial goods, without change of their identity as such goods, are merely subjected to some processing or finishing or are merely joined together, they may remain commercially the same goods which cannot be taxed again, in a series of sales, so long as they retain their identity as goods of a particular type. In the present case dressed hides and skins is a separate commercial commodity which emerges after raw hides and skins has been subjected to manufacturing process and, therefore, section 14(iii) deals with two different types of goods which unlike the case of pulses referred to in section 15(d), is not regarded by the Act as one and the same commodity." The learned counsel for the petitioners relied on State of Tamil Nadu v. O. P. Aliyar [1992] 87 STC 339 (Mad.), but this judgment will not apply to the facts of the present case as there were no two separate entries for bigger stones and smaller stones. Had there been only one entry in the Schedule I of the APGST Act, perhaps there would have been no difficulty in accepting the contention of the learned counsel for the petitioners but since there are two different entries for "raw granite stone" and "polished granite stone" the judgment will not come to their rescue. The Karnataka High Court judgment in Poonam Stone Processing Industries v. Deputy Commissioner of Commercial Taxes (Admn.), Gulbarga [1994] 94 STC 183 would also not apply to the facts of the present case for the reasons given hereinabove. For the reasons given above, we dismiss the writ petitions. No costs. Petitions dismissed.