Common parlance rule limits concessional tax entries: rajmash and lobia were outside the named pulse category.

Taxing entries are construed in common parlance, not in a technical or botanical sense, and a concessional sales tax notification will be limited to the goods expressly enumerated. Applying that approach, the term "mash" in item No. 21 could not be expanded to include rajmash or lobia, because the notification separately listed specific pulses and did not cover unmentioned varieties. Rajmash and lobia were therefore outside item No. 21, and the concessional rate was not available. The interpretation confirmed that where a notification names particular commodities, other varieties are excluded unless they clearly fall within the ordinary commercial meaning of the named item.

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Issues: Whether rajmash and lobia were covered by item No. 21 of the concessional sales tax notification as mash or dried peas.

Analysis: Taxing entries are to be construed in common parlance and not in a technical or botanical sense. The expression mash in item No. 21 could not be stretched to include rajmash or lobia. The notification specifically listed several kinds of pulses, which indicated an intention to confer the concessional rate only on the commodities expressly mentioned and not on other unenumerated varieties.

Conclusion: Rajmash and lobia were not covered by item No. 21 and the concessional rate was not available. The question was answered in the affirmative, against the assessee and in favour of the Revenue.

Ratio Decidendi: A taxing entry must be construed according to its popular meaning in common parlance, and where a notification specifically enumerates certain goods, unmentioned varieties are excluded unless they clearly fall within the ordinary commercial understanding of the named item.

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