Common parlance meaning of "vegetable" brought dhania and matar seeds within the exemption for vegetable seeds.

In taxing statutes, the term "vegetable" is to be understood in its common parlance sense, meaning the understanding of persons conversant with the subject matter. Applying that approach, dhania and matar seeds were treated as seeds of vegetable because the notification exempted seeds, plants and bulbs of vegetables. The goods therefore fell within the exemption, and the seeds of dhania and matar were entitled to exempt treatment under the notification.

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Issues: Whether seeds of dhania and matar fall within the expression "seeds of vegetable" so as to qualify for exemption under the relevant notification.

Analysis: In taxing statutes, the word "vegetable" is to be understood in its common parlance sense, namely, the meaning attributed to it by persons conversant with the subject-matter. Applying that approach, seeds of dhania and matar were held to be seeds of vegetable. As the notification exempted seeds, plants and bulbs of vegetables, the goods in question were within its ambit.

Conclusion: The seeds of dhania and matar were entitled to exemption as seeds of vegetable.

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