Commercial meaning governs tax exemptions: denatured spirit is outside the tax-free liquor entry under sales tax law.

Denatured spirit was held not to fall within Serial No. 12 of the tax-free goods schedule under the Orissa Sales Tax Act because the listed items were beverage or intoxicant goods, and exemption entries must be construed by popular or commercial meaning. In the absence of a statutory definition, meanings from the Bihar and Orissa Excise Act, 1915 or the Orissa Prohibition Act, 1956 could not be imported into the sales tax exemption. On ordinary parlance, denatured spirit is used for painting and varnishing rather than for consumption, so it was outside the exemption entry.

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Issues: Whether denatured spirit falls within Serial No. 12 of the schedule of tax-free goods under the Orissa Sales Tax Act, 1947.

Analysis: The expression in Serial No. 12 covered country liquor, potable foreign liquor, medicated wines, excise opium, ganja and bhang, all of which were items of beverage or intoxicant use. In the absence of any definition of denatured spirit in the Act, the meaning could not be borrowed from the Bihar and Orissa Excise Act, 1915 or from the Orissa Prohibition Act, 1956 for construing a fiscal exemption. The proper approach in sales tax law was the popular or commercial meaning, and in ordinary parlance denatured spirit was used for painting and varnishing, not as a beverage or intoxicant.

Conclusion: Denatured spirit does not fall within Serial No. 12 and is not tax-free under the exemption entry.

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