Popular commercial meaning governs sales tax classification; Tinopal falls under washing materials, not the general chemical entry.

Sales tax classification of Tinopal turned on the popular or commercial meaning of the goods, not their scientific character. The notification dated 1 December 1962 treated washing materials as a specific entry and chemicals as a general entry. Because Tinopal is commonly used for washing textiles and clothes and its whitening function serves that washing use, the specific entry for washing materials prevailed. Tinopal was therefore classified under item No. 32 as a washing material taxable at 4 per cent, and not under the chemical entry taxable at 7 per cent.

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Issues: Whether Tinopal fell under the entry for chemicals taxable at 7 per cent. or under the entry for washing materials used for washing purposes taxable at 4 per cent. under the notification dated 1st December, 1962.

Analysis: The applicable approach for interpreting sales tax entries is the popular or commercial meaning of the goods, not their scientific or technical character. The notification dated 1st December, 1962 created a separate and specific classification for washing materials, while chemicals continued as a general entry at 7 per cent. Where an article is specifically covered by the washing materials entry, that specific entry governs even if the article may also be a chemical. Tinopal is commonly used for washing textiles and clothes and its whitening function is part of that washing use.

Conclusion: Tinopal is a material used for washing purposes within item No. 32 and is taxable at 4 per cent. It is not taxable as a chemical under item No. 4.

Final Conclusion: The reference was answered in favour of the assessee by holding that Tinopal falls under the special entry for washing materials rather than the general entry for chemicals.

Ratio Decidendi: For sales tax classification, a specific entry for goods used for washing purposes prevails over a general entry for chemicals, and classification must be made according to the goods' popular or commercial understanding.

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