Common parlance test excludes rexine-coated fabric from textile exemption where the finished product loses its original commercial identity.

Rexine-coated cotton fabric was held not to fall within the textile entry in the Pondicherry General Sales Tax Act because the coating altered the finished article's commercial identity. The Court applied the common parlance test and the earlier approach excluding waterproof and similar coated fabrics from textile entries, and held that the entry must be construed on its own terms rather than by borrowing meanings from other statutes. On the facts, the product had lost its original textile character and became a distinct commercial commodity, so the exemption claim failed.

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Issues: Whether rexine-coated cotton fabric is a textile within entry 31 of the Third Schedule to the Pondicherry General Sales Tax Act, 1967 and therefore eligible for exemption.

Analysis: The product was examined as a finished commodity made from cotton fabric as base material with a coating that altered its character. The governing approach was whether the finished article continued to be a textile in common parlance. The earlier binding reasoning treating waterproof cloth and similar coated fabrics as outside the scope of textile entries was applied. The Court held that the entry must be construed on its own terms and not by borrowing meanings from other statutes. Although use is not the decisive factor, the material question remained whether the finished article retained the identity of textile. On the facts, the coated fabric had lost its original character and became a different commercial product.

Conclusion: Rexine-coated cotton fabric is not a textile within entry 31 and the exemption claim fails.

Final Conclusion: The tax revision was rejected because the finished product was held taxable as a distinct commercial commodity and not as textile.

Ratio Decidendi: A coated fabric ceases to fall within a textile entry when, in common parlance and commercial identity, the finished product is no longer regarded as textile but as a different commodity.

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