Popular meaning of "carpet" prevails: durrets fall outside the notification entry and are taxed as unclassified goods.

The Allahabad HC applied the popular and commercial meaning of "carpet" because the term was not defined in the statute or rules. It held that ordinary usage, dictionary meaning and trade understanding controlled, and on that basis durrets, being woven cotton fabrics with a fluffy surface on both sides, did not answer the accepted meaning of carpets, which are commonly understood as woollen, knotted articles. The court also noted that carpets and durries were separately dealt with in the notifications, indicating that durrets were an intermediate article outside the carpet entry. Durrets were therefore treated as unclassified goods taxable at the general rate.

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Issues: Whether durrets fall within the term "carpets" in the relevant sales tax notification, or are to be treated as unclassified goods taxable at the general rate.

Analysis: The word "carpet" was not defined in the statute or rules and therefore had to be understood in its popular and commercial sense. The court treated the ordinary meaning, dictionary usage, and trade understanding as controlling. On the facts, durrets were found to be woven cotton fabrics with a fluffy surface on both sides, differing from carpets in the accepted sense and not matching the woollen, knotted carpet commonly understood in sales tax notifications. Since carpets and durries were separately dealt with in notifications, durrets were regarded as an intermediate article not covered by the notification entry for carpets.

Conclusion: Durrets are not carpets within the notification and are taxable as unclassified goods at the general rate.

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