Commercial classification of lignite briquettes as coal, not charcoal, controlled their treatment under the declared-goods entry.

Lignite briquettes were classified as coal, not charcoal, for purposes of the declared-goods entry under the Central Sales Tax Act and the corresponding Tamil Nadu sales tax schedule. The Court applied the popular and commercial meaning of the commodity, noting that coal includes lignite in its commercial and scientific sense, while charcoal denotes carbonised wood or timber. The briquetting process did not change the essential character of the product. On that basis, leco fell within the declared-goods entry and outside the charcoal exclusion, and the assessment treating it as taxable was sustained.

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Issues: Whether leco, being lignite briquettes, falls within coal as declared goods under section 14(i) of the Central Sales Tax Act, 1956, or whether it is charcoal and therefore outside the declared-goods entry.

Analysis: Section 14(i) treats coal, including coke in all its forms, as goods of special importance, while excluding charcoal. The corresponding entry in the Second Schedule to the Tamil Nadu General Sales Tax Act, 1959 also uses the same formulation. On the materials considered, lignite was treated as a form of coal in its commercial and scientific sense, and the administrative clarifications referred to in the judgment had also proceeded on that basis. The word charcoal was held to connote carbonised wood or timber in its popular sense, and the process by which lignite briquettes are made did not alter their essential character as a coal product.

Conclusion: Leco, being lignite briquettes, is coal and not charcoal, and is therefore covered by the declared-goods entry.

Final Conclusion: The revision petition was unsuccessful and the assessment treating the commodity as taxable was sustained.

Ratio Decidendi: Where a tariff or sales-tax entry uses a commercial expression not defined exhaustively, the commodity must be classified according to its popular and commercial understanding; on that test, lignite briquettes fall within coal and not within charcoal.

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