Commercial and popular meaning governs classification of ultramarine blue as a pigment, not a chemical, for sales tax purposes.

Ultramarine blue was classified as a pigment, not a chemical, for sales tax purposes under the Tamil Nadu General Sales Tax Act. The Court relied on dictionary meanings, commercial understanding, trade usage, and prior High Court decisions to conclude that the product is commonly known and used as a colourant or whitener. On that basis, the specific pigment entry applied instead of the residuary chemical entry, and the sales tax authorities' classification was upheld.

---

---

Issues: Whether ultramarine blue or neel is a pigment falling under item 110 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, or a chemical falling under item 138.

Analysis: The product was examined in the light of dictionary meanings, commercial understanding, and prior decisions of other High Courts. Earlier decisions showing that ultramarine blue is a pigment and is used as a colourant or whitener supported the Revenue's classification. The Court accepted that, both by its physical character and by its use in trade and popular understanding, ultramarine blue is understood as a pigment and not as a separate chemical description under the residuary item.

Conclusion: Ultramarine blue is a pigment and is taxable under item 110, not item 138.

Final Conclusion: The classification adopted by the sales tax authorities was upheld and the assessees' challenge failed.

Ratio Decidendi: For tariff classification, a product is to be understood according to its commercial and popular meaning, and where the evidence shows that it is commonly known and used as a pigment or colourant, it falls under the specific pigment entry rather than the residuary chemical entry.

---