Common parlance classification rule: water-coolers are taxable as electrical goods, not refrigerators or air-conditioning plants.

Sales tax entries must be construed in their popular and commercial sense unless the statute requires a technical meaning. Applying common parlance, water-coolers were treated as distinct from refrigerators and air-conditioning plants because the market understands them as serving different functions. On that basis, water-coolers did not fall within entry No. 9 of the Kerala General Sales Tax Act, 1963, and were classifiable under entry No. 26 as electrical goods.

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Issues: Whether water-coolers fall within entry No. 9 of the First Schedule to the Kerala General Sales Tax Act, 1963 as "refrigerators and air-conditioning plants" or fall under entry No. 26 as electrical goods.

Analysis: The expressions in the sales tax entries had to be construed in their popular and commercial sense, not in a technical, scientific or dictionary sense. Water-coolers and refrigerators were understood in common parlance as distinct goods serving different purposes. The commercial world would not treat a water-cooler as a refrigerator, and the legislative entries had to be applied according to that ordinary commercial understanding.

Conclusion: Water-coolers do not fall under entry No. 9 and are taxable under entry No. 26 as electrical goods. The assessee succeeds on the classification issue.

Ratio Decidendi: Words used in sales tax entries must be construed according to their common commercial meaning unless the statute indicates a technical or scientific sense.

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