Popular trade meaning of "artificial silk fabrics" extended sales tax exemption to plain HDPE fabrics.

Plain HDPE fabrics were treated as covered by the sales tax exemption for "rayon or artificial silk fabrics" because product descriptions in revenue statutes are understood in their popular or trade sense, not a scientific or technical sense. The Tribunal's finding that the fabrics were regarded in trade as artificial silk was accepted, and the fact that they were made from tapes rather than yarn did not change their exempt character, especially without any contrary finding on the nature of the tapes. The fabrics were therefore not liable to tax.

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Issues: Whether plain HDPE fabrics were covered by the exemption for "rayon or artificial silk fabrics" under the sales tax notification and, therefore, not liable to tax.

Analysis: The dispute turned on the meaning of the expression "artificial silk fabrics" in the exemption notification. The Court applied the principle that, in revenue statutes, product descriptions are to be understood in their popular or trade meaning rather than in a scientific or technical sense. On the evidence before the Tribunal, the fabrics were found to be understood in as artificial silk by those dealing in them. The mere fact that the fabrics were manufactured from tapes and not from yarn did not displace that finding, especially when no contrary finding was recorded regarding the nature of the tapes themselves.

Conclusion: Plain HDPE fabrics fell within the exempted category of artificial silk fabrics and were not taxable.

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