Common parlance test for taxing entries: mill-made sataranjis treated as carpets, not fabrics, under separate notification entries.

Mill-made sataranjis are carpets in their ordinary and popular sense, so they fall within the specific carpet entry and not within the broader category of mill-made fabrics. Because the taxing notifications used separate and distinct entries, they had to be construed harmoniously so that neither became redundant; reading carpets as part of fabrics would make the carpet entry otiose. Applying common parlance, and relying on the Tribunal's finding, the court treated sataranjis as carpets and held that they were excluded from the mill-made fabrics entry, with the issue answered in favour of the Revenue.

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Issues: Whether mill-made sataranjis are carpets falling within item 40 of Finance Department Notification No. 33927 C.T.A. 130/57-F dated 30th December, 1957, and are therefore outside item 33 relating to mill-made fabrics in Finance Department Notification No. 33925 C.T.A. 130/57-F dated 30th December, 1957.

Analysis: The expression "carpets" was not defined in the taxing statute and was therefore to be understood in its ordinary, popular sense. The scheme of the notifications showed two distinct and separate entries, and they had to be construed harmoniously so that neither became redundant. If carpets were treated as falling within the wider expression "fabrics" in item 33, item 40 would be rendered otiose. The accepted common parlance meaning of carpet included sataranji, and the Tribunal's finding that sataranjis are carpets supported that conclusion.

Conclusion: Sataranjis are carpets, they fall within item 40, and they are excluded from item 33; the question is answered in favour of the Revenue.

Ratio Decidendi: Where a taxing schedule contains separate entries, the entries must be construed harmoniously in common parlance, and a specific entry prevails so that it is not nullified by a broader general description.

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