Popular meaning controls classification: armature coil winding oil used as adhesive was not treated as varnish.

Armature coil winding oil used as an adhesive in coil winding was held not to be varnish for classification under item 110 of the First Schedule to the Tamil Nadu General Sales Tax Act. The court applied the popular, ordinary meaning of "varnish" and noted that varnish is ordinarily associated with polishing, not adhesive use. The licensing regime under the Tamil Nadu Denatured Spirit Methyl Alcohol and Varnish (French Polish) Rules, 1959, also distinguished varnish from other denatured-spirit products, and the assessee's licence did not authorise manufacture of varnish. The reference to insulating spirit varnish in Indian Standards was treated as non-conclusive.

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Issues: Whether armature coil winding oil is classifiable as varnish under item 110 of the First Schedule to the Tamil Nadu General Sales Tax Act.

Analysis: The article was used as an adhesive in armature coil winding and not for polishing, which is the ordinary function associated with varnish. The licensing regime under the Tamil Nadu Denatured Spirit Methyl Alcohol and Varnish (French Polish) Rules, 1959, also distinguished varnish from other products manufactured from denatured spirit, and the assessee held a licence that did not authorise manufacture of varnish. Reference in Indian Standards Specification to insulating spirit varnish was not treated as conclusive. The expression in the statute had to be understood in its popular sense as ordinarily understood by a common man, and in that sense an adhesive could not be equated with varnish.

Conclusion: Armature coil winding oil is not varnish and does not fall under item 110 of the First Schedule to the Tamil Nadu General Sales Tax Act.

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