Popular sense of textiles governs classification, so woven hair-belting and cotton-belting were treated as exempt textiles.

Textile entries under the Tamil Nadu General Sales Tax Act were construed in their popular and ordinary sense as woven fabrics, not in a narrow technical sense. The end use of the material was held irrelevant; what mattered was whether the product was manufactured as a fabric. Applying that principle, hair-belting and cotton-belting were treated as textiles rather than parts or accessories of machinery. Their turnover therefore fell within item 4 of the Third Schedule and was exempt from tax, not taxable under item 81 of the First Schedule.

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Issues: Whether hair-belting and cotton-belting fell within item 4 of the Third Schedule to the Tamil Nadu General Sales Tax Act, 1959 as textiles exempt from tax, or were taxable as parts and accessories of machinery under item 81 of the First Schedule.

Analysis: The expression "textiles" was construed in its popular and ordinary sense as a woven fabric, and not in any narrow technical sense. The governing principle was that the use of the material is irrelevant, while the character of the product as a textile depends on its manufacture as a fabric. Earlier authority on dryer felts and the later classification of cotton fabrics and woollen fabrics supported the wider understanding of textiles. On that basis, hair-belting and cotton-belting were treated as falling within the textile entry rather than the machinery entry.

Conclusion: The turnover relating to hair-belting and cotton-belting was exempt under item 4 of the Third Schedule and not taxable under item 81 of the First Schedule.

Ratio Decidendi: Textile entries must be interpreted in their popular sense, and products manufactured as woven fabrics remain textiles irrespective of their end use.

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