Guar meal as fodder, not flour, qualifies for sales tax exemption under the relevant schedule entry.

Guar giri or guar meal manufactured from guar grain is described as a by-product obtained by separating husk from kernel, not a finely ground flour in ordinary parlance. Because the commodity was shown to be used only as cattle feed, its character was determined by common commercial understanding and its established use. On that basis, the article states that guar meal answers the description of fodder, not guar flour, and falls within the sales tax exemption for fodder under Schedule B, rather than the taxing entry for guar flour.

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Issues: Whether guar giri or guar meal manufactured from guar grain is assessable to sales tax as guar flour or is exempt as fodder under the sales tax exemption entry.

Analysis: Guar and its flour had earlier been included as a separate exempt entry in Schedule B, while fodder of every type was later added as another exempt item. The subsequent omission of guar and its flour from the exempt schedule and its inclusion in the taxing notification showed that guar as such could be taxed, but only if the product answered the description of guar flour. The substance produced by the petitioners was not flour in the ordinary sense: it was a by-product obtained by separation of the husk from the kernel, not a finely ground powder. It was also not shown to have any use other than as cattle feed. In taxing statutes, words not defined in the Act must be understood in their common parlance, and where the commodity has only one established use, that use is material in determining its character.

Conclusion: Guar giri or guar meal is fodder and not guar flour, and it is exempt from sales tax under item 54 of Schedule B to the Act.

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