Ordinary trade understanding test denied sales tax exemption for chicken feed made from damaged wheat grains.

Murghi dana sold as chicken feed, though composed largely of damaged wheat grains with some vegetable matter, was held not to fall within the exempt entries for wheat or wheat flour under the sales tax law. The court applied the ordinary trade and common understanding test, holding that the product must be identified as the commodity named in the Schedule and not merely by its constituent ingredients. Because murghi dana could not be sold, used, or ordinarily mistaken for wheat or wheat flour, it was outside the exemption and remained taxable.

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Issues: Whether murghi dana, sold as chicken feed and composed largely of damaged wheat grains with some vegetable matter mixed in, fell within the exempt entries of wheat or wheat flour under the sales tax law.

Analysis: The commodity was not named in the Schedule. The decisive test was how the article was understood in ordinary trade and by an ordinary person, not whether it was largely made up of wheat in its last analysis. Murghi dana could not be sold as wheat or wheat flour, nor used as either, and would not ordinarily be confused with them.

Conclusion: Murghi dana was neither wheat nor wheat flour and was not exempt from sales tax. The appeal was therefore allowed and the plaintiffs' suit stood dismissed.

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