Ordinary and popular meaning of "carpet" governed classification, placing the commodity outside the textile exemption.

The term "carpet" in Entry 30 of Schedule B was construed in its ordinary and popular sense, supported by dictionary meaning, rather than a narrow technical meaning. On the facts, the assessee described the commodity as carpet in cash-memos, admitted it was sold in the market as carpet, and the material showed it to be a thick woven floor-covering, even if laid above a duree. The consistent view of the taxing authorities was a factual finding that should not have been disturbed in writ jurisdiction. The commodity was treated as carpet and was outside the textile exemption.

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Issues: Whether the commodity sold by the assessee was a "carpet" within Entry 30 of Schedule B to the Punjab General Sales Tax Act and therefore excluded from the textile exemption.

Analysis: The commodity was described by the assessee himself as carpet in the cash-memos, and the assessee admitted that it was ordinarily sold in the market as carpet. The material on record showed that it was a thick woven article used for spreading on the floor, even if placed above a duree. In construing the statutory word, the ordinary and popular sense had to be applied, and the dictionary meaning supported inclusion within the term. The consistent finding reached by the taxing authorities was a finding of fact that ought not to have been disturbed in writ jurisdiction.

Conclusion: The commodity was a carpet and fell outside the exemption under Entry 30; the determination was against the assessee and in favour of the Revenue.

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