Hair-dye not treated as hair lotion under sales tax entry; common parlance and commercial sense controlled interpretation.

Hair-dye was held not to fall within the expression "hair lotion" in entry 36 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957. The expression "cosmetics and toilet preparations" was read in its common parlance and commercial sense because the Act did not define it, and "lotion" was understood as a liquid preparation used externally for cleansing, soothing, medicinal, or cosmetic purposes. Hair-dye, being a colouring material used to blacken grey hair for beautification, was therefore not treated as a hair lotion or taxable cosmetic/toilet preparation under that entry.

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Issues: Whether hair-dye falls within the expression "hair lotion" in entry 36 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 and is therefore taxable as a cosmetic or toilet preparation.

Analysis: The expression "cosmetics and toilet preparations" in the entry was treated as an exhaustive enumeration of the specified items. As the Act did not define the expression, the words had to be understood in their common parlance and commercial sense rather than in a technical sense. On that approach, "lotion" denotes a liquid preparation applied externally, ordinarily for cleansing, soothing, medicinal, or cosmetic purposes. Hair-dye, by contrast, is a colouring material used to blacken grey hair for beautification and not as a medicinal preparation for cleansing the hair or treating skin disorders.

Conclusion: Hair-dye is not hair lotion within entry 36 and is not taxable under that entry.

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