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Issues: Whether glass sheets sold under the cash memos were covered by entry No. 14 of Schedule C as "glassware", or by the residuary entry No. 22 of Schedule E.
Analysis: The governing test for construing goods entries in a sales tax schedule is the sense in which the commodity is understood in trade parlance or common parlance. Where evidence is led on the commercial understanding of the term, that evidence is decisive; dictionary meaning is a subsidiary aid and is relevant only when trade evidence is unavailable. On the evidence before the taxing authority, the Tribunal found that traders and manufacturers treated "glass" and "glassware" as distinct categories and that sheet glass was not included in "glassware". That finding was consistent with the applicable legal test and with the earlier authorities on commercial interpretation of sales tax entries.
Conclusion: Glass sheets were not covered by "glassware" in entry No. 14 of Schedule C and therefore fell under the residuary entry No. 22 of Schedule E. The question was answered in favour of the assessee and against the Revenue.