Commercial meaning of goods governs sales tax classification, and sodium silicate was treated as a taxable chemical.

In construing a sales tax notification, goods must be classified according to their commercial or trade meaning rather than a narrow scientific definition. Applying that approach, sodium silicate was treated as a chemical because it was marketed and understood in trade as such. On that basis, it fell within the expression "chemicals of all kinds" in the relevant notification and was liable to tax under the U.P. Sales Tax Act.

---

---

Issues: Whether sodium silicate falls within the expression "chemicals of all kinds" in item No. 7 of Notification No. ST-905/X dated 31st March, 1956, so as to attract sales tax under the U.P. Sales Tax Act.

Analysis: The notification issued under Section 3-A of the U.P. Sales Tax Act fixed single-point taxation for specified goods, including "chemicals of all kinds". The term had to be construed not in a scientific or technical sense, but in the commercial sense in which dealers and purchasers in the trade would understand it. In fiscal statutes, classification of goods depends on popular and trade understanding, not on strict scientific definition. Sodium silicate was shown to be marketed and used as a chemical, and its commercial characteristics brought it within the ordinary trade meaning of chemicals.

Conclusion: Sodium silicate is included in "chemicals of all kinds" in item No. 7 of the notification and is liable to tax accordingly.

Final Conclusion: The reference was answered in favour of the revenue, and the questioned commodity was held taxable under the notification.

Ratio Decidendi: In interpreting entries in a sales tax notification, goods must be classified according to their commercial or trade meaning, and not by a narrow scientific test.

---