Common parlance test limits sales tax exemption: processed palm oil is not covered by "palm products".

For sales tax exemption entries, goods are construed in their common parlance and commercial sense rather than by a purely literal or dictionary meaning. Palm oil, being a processed product obtained after crushing palm, was treated as having a distinct identity from the raw source, and the notification's wording did not clearly extend the exemption to it. The separate mention of palm-gur also supported that only directly derived palm articles were intended. On that basis, palm oil was not included within "palm products" and was not exempt from sales tax.

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Issues: Whether palm oil falls within the expression "palm products" in the exemption notification issued under the Bihar Sales Tax Ordinance so as to exempt it from sales tax.

Analysis: The exemption had to be construed according to the sense in which the goods were understood in common parlance, especially in commercial circles, rather than by a merely literal or dictionary approach. Palm oil is obtained after processing and crushing palm, and a processed product does not remain the same as its raw source merely because it is derived from it. The expression used in the Hindi version also indicated only articles directly derived from palm in its natural state, and the setting of the exemption showed that "palm-gur" was separately mentioned because it was a distinct processed article. On that basis, palm oil could not be treated as included in "palm products".

Conclusion: Palm oil is not covered by the expression "palm products" and is not exempt from sales tax under the notifications.

Ratio Decidendi: For sales tax exemption entries, the decisive test is the commercial and common parlance understanding of the goods, and a processed article that has changed its identity is not included within the description of its raw source unless the notification clearly says so.

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