Commercial meaning of cinder excludes it from coal classification, making its sale subject to multi-point tax.

Cinder is treated in commercial parlance as the residue or ash left after coal or coke is burnt, so it is not classified as coal for sales tax purposes. The relevant description must be understood according to its ordinary commercial meaning, and a purchaser of coal would not regard cinder as coal. On that basis, the prior view that cinder is not coal was reaffirmed, and its sale was held liable to multi-point tax.

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Issues: Whether cinder is coal for the purpose of sales tax classification and whether its sale is subject to multi-point tax.

Analysis: Cinder was held to be the residue or ash left after coal or coke is burnt and, in commercial understanding, it is not treated as coal. The word was required to receive its commercial meaning, and a purchaser of coal would not treat cinder as coal. The prior view that cinder is not coal was affirmed.

Conclusion: Cinder is not coal, and its sale is liable to multi-point tax. The decision was against the assessee.

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