As per case facts, the Petitioner, engaged in works contracts for a rail-cum-road bridge, purchased structural steel and fabricated it into a superstructure. They filed returns, claiming deductions for labor ... and input tax credit, and paid tax at 5 percent on the structural steel, classifying it as "iron and steel" under Section 14(4) of the CST Act. The Respondent, however, initiated reassessment, asserting that the fabricated 'steel structures' were unspecified goods liable to 13.5% tax and that the claimed deductions for fabrication and labor were part of the goods' cost. The Petitioner also challenged the reassessment as a mere change of opinion and argued that subcontractor turnover should be deducted. The question arose whether the fabricated steel superstructure retained its identity as "iron and steel" or became a distinct commercial commodity, and if related labor/fabrication costs were deductible or part of the taxable goods' value. Finally, the Court, citing Gannon Dunkerley and Quippo Energy Limited judgments, held that the structural steel undergoes significant transformation and passes marketability tests post-fabrication and installation, thus becoming a distinct commercial commodity. The Court upheld the Respondent's rejection of deductions for transportation, launching, installation, and fabrication as these were integral to the cost of the steel structure transferred.