Commercial parlance governs tax-free classification of monoblock centrifugal pumps; reassessment notices treating them as taxable were quashed.

A monoblock centrifugal pump was held to fall within the expression "centrifugal pump" in item 34-D of Schedule B to the Punjab General Sales Tax Act, because the entry had to be construed in its commercial or common parlance sense and not by a narrow technical distinction between pump and motor as separate parts. As the pump was manufactured and marketed as a single, inseparable unit, no basis existed to exclude that variety from a tax-free entry that covered centrifugal pumps generally. On that construction, the departmental memorandum treating such pumps as taxable and the notices reopening completed assessments could not be sustained and were quashed.

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Issues: Whether a monoblock centrifugal pump falls within the expression "centrifugal pump" in item 34-D of Schedule B to the Punjab General Sales Tax Act, 1948 and is therefore exempt from sales tax, and whether the departmental memorandum and notices issued to reopen assessments were sustainable.

Analysis: Item 34 of Schedule B, as amended, specifically included "centrifugal pump" among power implements declared tax-free. The decisive test was the commercial or common parlance meaning of the entry, not a narrow technical distinction between a pump sold separately and a pump fitted with a motor as one marketable unit. A monoblock centrifugal pump was found to be a single, inseparable, marketable commodity manufactured as one unit, and the statutory scheme did not indicate any intention to exclude one variety of centrifugal pump while including another. On that construction, a monoblock centrifugal pump remained a centrifugal pump within the entry and was exempt from tax. Once that conclusion followed, the departmental memorandum treating such goods as taxable and the notices for revising completed assessments could not stand.

Conclusion: A monoblock centrifugal pump is covered by item 34-D and is tax-free, and the memorandum and notices impugned in the writ petitions were liable to be quashed.

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