Popular meaning governs undefined taxing entries: portable steel trunks were treated as suit-cases and kept out of the residuary entry.

Undefined taxing entries must be construed in their ordinary and popular sense, not by the material of the article. Applying that test, an item is covered if it answers the commercial description used in the schedule in common parlance and is an easily portable article used for carrying clothes on a journey. On that reasoning, steel trunks of suitable size and portability fell within the expression "suit-cases" in entry 12 of Schedule E and were excluded from the residuary entry 22.

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Issues: Whether steel trunks sold by the applicants were included in the expression "suit-cases" in entry 12 of Schedule E of the Bombay Sales Tax Act, 1959, or fell under the residuary entry 22 of Schedule E.

Analysis: The expression "suit-cases" was not defined in the Act and therefore had to be construed in its ordinary, popular sense as understood by persons conversant with the subject-matter. The decisive test was not the material of which the article was made, but whether it was an easily and conveniently portable article used for carrying clothes on a journey. On that test, trunks that were of a size and portability suitable for travel could fall within the ordinary meaning of "suit-cases".

Conclusion: The steel trunks sold by the applicants were suit-cases within entry 12 of Schedule E and were not taxable under the residuary entry 22.

Ratio Decidendi: Where a taxing entry uses an undefined commercial article, the term must be interpreted in its popular or ordinary sense, and an article is covered if it answers that commercial description in common parlance.

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