Commercial parlance test controls classification of pulleys, excluding iron and steel and machine parts but including hardware.

Pulleys were held not to fall within "iron and steel" under section 14(iv) of the Central Sales Tax Act because the entry is exhaustive and a pulley is commercially distinct from a wheel. They were also held not taxable as machine parts, following prior authority on ordinary pulleys used for power transmission. However, pulleys were treated as taxable as hardware and mill stores on commercial parlance reasoning, since iron pulleys were accepted within that category. The stated ratio is that a specific tariff entry must be applied according to its ordinary and commercial meaning, and a finished article cannot be treated as a component merely because it contains that component.

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Issues: (i) Whether pulleys fall within "iron and steel" under section 14(iv) of the Central Sales Tax Act; (ii) Whether pulleys are taxable as machine parts; (iii) Whether pulleys are taxable as hardware and mill stores.

Issue (i): Whether pulleys fall within "iron and steel" under section 14(iv) of the Central Sales Tax Act.

Analysis: Section 14(iv) is an exhaustive enumeration of separate taxable goods. The term "wheels" in sub-clause (xiv) cannot be stretched to include a pulley, because a pulley is not a wheel pure and simple but a wheel with grooves and an added mechanical function. Applying the ordinary and commercial meaning of the expression, a pulley remains distinct from a wheel and therefore does not answer the statutory description of "iron and steel".

Conclusion: Pulleys do not fall within "iron and steel" under section 14(iv) of the Central Sales Tax Act and the view treating them as such is wrong.

Issue (ii): Whether pulleys are taxable as machine parts.

Analysis: The question was covered by earlier authority holding that ordinary pulleys used for transmission of power are not liable to be taxed as machine parts at the relevant notified rate.

Conclusion: Pulleys are not taxable as machine parts.

Issue (iii): Whether pulleys are taxable as hardware and mill stores.

Analysis: In commercial parlance, hardware comprises small metal goods, and mill stores and hardware are allied trades. Earlier decisions had treated iron pulleys as falling within that category, and the material on record supported that commercial classification.

Conclusion: Pulleys are taxable as hardware and mill stores.

Final Conclusion: The classification made by the revising authority was upheld only to the extent that pulleys were treated as hardware and mill stores, and the departmental revision succeeded.

Ratio Decidendi: Where a tariff entry enumerates specified commodities exhaustively, a product can be classified only if it answers the ordinary and commercial meaning of the specified item, and a distinct finished article cannot be equated with one of its component parts merely because it contains that component.

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