Commercial meaning of firewood controls sales tax exemption where wood is supplied as industrial pulpwood, not fuel wood.

Wood sold under contractual specifications for debarking, splitting to size, and removal of knots, forks, and rot was treated as pulpwood for industrial use, not firewood. The exemption notification applied only to firewood, and the ordinary trade meaning of that term covered wood bought and sold as fuel. Because the goods were commercially and functionally different from fuel wood, they did not fall within the exemption. The exemption was therefore unavailable, and the issue was decided in favour of the Revenue and against the assessee.

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Issues: Whether the wood sold under the sale specifications could be treated as firewood and thereby qualify for exemption from sales tax under the Government notification.

Analysis: The exemption notification granted relief only for firewood and did not define the expression. The deciding factors were the contractual specifications and the ordinary commercial meaning of the goods. The wood sold was required to be debarked, split to size, and free from knots, forks, and rot, showing that it was intended as pulpwood for manufacture of rayon or similar fibre, not as fuel wood. In common trade usage, firewood is wood ordinarily bought and sold as fuel, and the presence of special processing or specifications directed to industrial use is inconsistent with that characterisation.

Conclusion: The goods were not firewood and the exemption was not available. The issue is decided in favour of the Revenue and against the assessee.

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