Commercial parlance governs tax classification of groundnut as an oil-seed, sustaining the purchase tax levy.

For tax classification under sales tax law, the expression "oil-seeds" is to be understood in commercial parlance rather than by dictionary meaning. Groundnut was shown to be treated in trade as an oil-seed, and it was also established that it germinates and is largely used for oil manufacture. On that basis, groundnut fell within the term "oil-seeds", the assessee's contrary contention failed, and the levy based on that classification was upheld.

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Issues: Whether groundnut is an oil-seed for the purpose of levy of purchase tax.

Analysis: The term "oil-seeds" in the sales tax law was required to be understood in commercial parlance and not by reference to dictionaries. Groundnut was shown to be dealt with in commercial circles as an oil-seed, and it was also established that it germinates and is largely used for the manufacture of oil.

Conclusion: Groundnut is an oil-seed. The assessee's contention to the contrary failed.

Final Conclusion: The appeal was dismissed and the levy based on treating groundnut as an oil-seed was upheld.

Ratio Decidendi: For tax classification, the meaning of a commodity in commercial parlance governs, and a seed that is commercially treated and substantially used as an oil-seed falls within that expression.

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