Commercial meaning of "paper" governs tax classification; chemically coated ammonia and ferro paper fall outside the paper category.

Where a taxing statute does not define "paper," classification must follow the ordinary, popular and commercial meaning understood by users and traders, not a scientific description. Ammonia paper and ferro paper were chemically coated papers used for obtaining prints and sketches of site plans, and their essential character was found to lie in the coating rather than the paper base. On that basis, they did not answer the common understanding of paper as material used for writing, printing or packing, and were therefore excluded from the paper category for sales tax purposes.

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Issues: Whether ammonia paper and ferro paper fall within the category of paper for the purpose of sales tax classification.

Analysis: The expression "paper" was not defined in the Act and had therefore to be understood in its ordinary, popular and commercial sense. Goods are to be classified according to how they are commonly understood by persons dealing in and using them, and not by their scientific or technical description. Ammonia paper and ferro paper were chemically coated papers meant for obtaining prints and sketches of site plans, and their essential character lay in the chemical coating rather than in the paper base. On that basis, they did not answer the popular meaning of paper as used for writing, printing or packing purposes.

Conclusion: Ammonia paper and ferro paper do not fall within the category of paper and are not taxable as paper under the notification.

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