Commercial meaning of fiscal entries keeps semi-manufactured glass rods and tubes outside "glassware" under sales tax notification.

A fiscal sales tax notification must be construed in its commercial sense, not by the widest dictionary meaning. On that approach, "glassware" covers finished glass articles ordinarily sold to consumers, not glass rods and glass tubes sold as raw material for further manufacture and remaining semi-manufactured goods. The surrounding entries also supported a finished-goods reading, and the wider revenue construction was rejected because it would create double taxation at successive stages under a single-point levy scheme. The Hindi expression "kanch ka saman" was treated as carrying the same commercial meaning, so there was no real conflict with the English text. Glass rods and glass tubes therefore fell outside the notification and were taxable as unclassified items at the general rate.

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Issues: Whether glass rods and glass tubes manufactured and sold by the assessee were classifiable as "glassware" under the relevant sales tax notification, or as unclassified items taxable under the general charging provision.

Analysis: The notification had to be construed in a commercial sense and not in its widest dictionary meaning. On that approach, "glassware" covered only finished articles of glass ordinarily sold to consumers. Glass rods and glass tubes in the present case were found to be sold as raw material to dealers for further manufacture and remained semi-manufactured goods. The surrounding entries in the notification also indicated that the notified items were finished goods. Accepting the revenue's wider construction would produce double taxation at successive stages, contrary to the scheme of single-point levy under the notification. The Hindi expression "kanch ka saman" was also held to bear the same commercial meaning and did not create any real conflict with the English version.

Conclusion: Glass rods and glass tubes were not "glassware" within the notification and were taxable as unclassified items at the general rate under section 3.

Ratio Decidendi: A fiscal entry in a sales tax notification must be construed in its commercial sense, and a semi-manufactured article sold as raw material for further manufacture does not fall within a category reserved for finished consumer goods.

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