Common parlance test governs sales tax classification of leco as charcoal for exemption.

A taxing entry must be construed in its ordinary commercial sense unless the statute uses technical language, and the Court applied the common parlance test to classify leco under the sales tax exemption for firewood and charcoal. Leco, though manufactured from lignite by briquetting and carbonisation, was understood in trade and by consumers as a domestic fuel corresponding to charcoal, and the manufacturer's own description of the product as fuel reinforced that understanding. Its geological or scientific origin was treated as irrelevant for classification under the entry. Leco was therefore held to fall within item 18 of Schedule III to the Pondicherry General Sales Tax Act and to be exempt from tax.

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Issues: Whether leco was classifiable as charcoal within item 18 of Schedule III to the Pondicherry General Sales Tax Act, 1967 and therefore entitled to exemption.

Analysis: In construing a taxing entry, the ordinary commercial meaning of the word prevails unless the statute uses a technical or scientific term. The relevant exemption covered firewood and charcoal. The Court applied the common parlance and commercial understanding test and held that leco, though produced from lignite by briquetting and carbonisation, was understood in trade and by consumers as domestic fuel corresponding to charcoal. The manufacturer's own description of the product as fuel also supported that understanding. The geological or scientific origin of the product was held to be irrelevant for classification under the sales tax entry.

Conclusion: Leco was held to be charcoal within the meaning of item 18 of Schedule III and was exempt from tax, so the assessee succeeded.

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