Common parlance classification of woollen blankets keeps them taxable, as exemption entries must be strictly proved.

Mill-made woollen blankets were classified as woollen goods rather than exempt mill-made fabrics because the term "fabric" was given its common parlance meaning in the absence of a statutory definition. Entry 46, covering woollen goods subject to specified exclusions, was read together with the exemption entry for mill-made fabrics wholly or partly made of wool. The burden remained on the assessee to prove that the exemption applied, and exemption provisions were construed strictly. On that construction, mill-made woollen blankets did not fall within the tax-free schedule and were taxable under the relevant entry.

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Issues: Whether mill-made woollen blankets fall within serial No. 33 of the schedule of tax-free goods or are taxable under entry No. 46 of the schedule of taxable commodities.

Analysis: The dispute turned on the meaning of the word "fabric" and the scope of the competing tariff entries. In the absence of a statutory definition, the term was to be understood in its common parlance sense. Entry 46 covered all woollen goods, except the specified exclusions, while entry 33 exempted mill-made fabrics wholly or partly made of wool. The two entries had to be read together, and the burden lay on the assessee to establish that the goods were exempt. On that construction, mill-made woollen blankets were treated as woollen goods and not as exempt mill-made fabrics.

Conclusion: Mill-made woollen blankets do not fall under serial No. 33 of the tax-free schedule and are taxable under the relevant taxable entry.

Ratio Decidendi: Where a commodity is claimed to be exempt from sales tax, the exemption entry must be strictly shown to apply, and in the absence of a statutory definition, the goods are classified according to their ordinary commercial meaning by reading the competing tariff entries together.

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