Common parlance governs sales tax classification, and rectification cannot reopen assessments based on later judicial views.

Crushed bone was not treated as fertilizer for sales tax purposes because the taxable description had to be determined by common parlance and commercial identity, and the materials did not show it was ordinarily known or sold as fertilizer. Rectification under section 22 could not be used to reopen an assessment merely because later judicial decisions had taken a different view, since rectification is limited to mistakes apparent from the record and is not a substitute for review. The assessment and related orders were set aside, leaving the classification question open for future cases.

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Issues: (i) Whether crushed bone is covered by the expression "fertilizer" for sales tax purposes; (ii) Whether the Assessing Authority could invoke rectification on the basis of subsequent judicial decisions.

Issue (i): Whether crushed bone is covered by the expression "fertilizer" for sales tax purposes.

Analysis: The question turned on the entries in the relevant sales tax notifications and on the ordinary commercial meaning of the goods. The distinction between bone meal and crushed bone was treated as material. The reasoning accepted that a commodity must be identified in common parlance and that technical or expert material is relevant where the taxable description is disputed. On the materials noticed, crushed bone was not shown to be ordinarily known or sold as fertilizer.

Conclusion: Crushed bone was not held to be fertilizer, and the assessee succeeded on this issue.

Issue (ii): Whether the Assessing Authority could invoke rectification on the basis of subsequent judicial decisions.

Analysis: Rectification under section 22 was considered in the light of the settled distinction between rectification of an apparent mistake and review. A power to rectify mistakes apparent from the record does not authorise reopening the matter merely because later decisions have taken a different view. The scope of rectification is confined to obvious errors and does not extend to substantive reconsideration of the assessment on changed legal opinion.

Conclusion: The rectification made by the Assessing Authority was not sustainable on this basis.

Final Conclusion: The assessment and the orders below were set aside, with the legal position on crushed bone left open for future cases.

Ratio Decidendi: For sales tax classification, the description of goods must be determined by common parlance and the relevant commercial identity, and rectification cannot be used as a substitute for review or for reopening an assessment merely because of later judicial decisions.

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