Commercial parlance test governs copra classification as an oil-seed, leaving it taxable despite the later amendment.

Copra was treated as an oil-seed for sales tax purposes under the Andhra Pradesh General Sales Tax Act because classification depends on ordinary commercial parlance, not a strict scientific germination test. On that basis, it fell within declared goods under section 14 of the Central Sales Tax Act and remained validly included in the Third Schedule. The later amendment referring to "coconuts of all varieties" and watery coconuts was read as not retrospectively removing copra from the levy, so copra continued to be taxable at the point of last purchase. The writ petitions therefore failed.

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Issues: (i) Whether copra is an oil-seed and thus declared goods liable to tax under item 5 of the Third Schedule read with section 6 of the Andhra Pradesh General Sales Tax Act. (ii) Whether the amending provision substituting "coconuts of all varieties" and inserting the item relating to watery coconuts excluded copra from levy at the point of last purchase.

Issue (i): Whether copra is an oil-seed and thus declared goods liable to tax under item 5 of the Third Schedule read with section 6 of the Andhra Pradesh General Sales Tax Act.

Analysis: Section 6 applies only to declared goods. The definition of declared goods refers to section 14 of the Central Sales Tax Act, 1956, and the relevant category is oil-seeds. The Court applied the ordinary commercial parlance test and held that copra is understood in trade as an oil-seed, not by a strict scientific test of germination. It preferred the view that dried coconut or copra falls within the expression oil-seeds.

Conclusion: Copra is an oil-seed within section 14(vi) of the Central Sales Tax Act, 1956, and its inclusion in item 5 of the Third Schedule is valid and consistent with section 6 of the Andhra Pradesh General Sales Tax Act.

Issue (ii): Whether the amending provision substituting "coconuts of all varieties" and inserting the item relating to watery coconuts excluded copra from levy at the point of last purchase.

Analysis: The amendment making specific retrospective provision applied only to watery coconuts, while the substitution of the entry for item 5 was not made retrospective. The expression "coconuts of all varieties" was held wide enough to include copra, and no basis was found to read the amendment as removing copra from the levy.

Conclusion: The amendment did not exclude copra from taxation, and copra remained taxable at the point of last purchase.

Final Conclusion: The writ petitions failed because copra was held to be taxable as declared goods, and the later amendment did not alter that position.

Ratio Decidendi: Classification of goods for sales tax purposes is to be determined by their ordinary commercial meaning, and where a commodity is commercially understood as falling within a taxable declared-goods category, its scientific inaptitude for germination does not exclude it from that category.

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