Commercial meaning of "wheel" extends to rims, excluding resort to the residuary sales tax entry.

Rims used in wheels of cycles and other vehicles were treated as falling within the specific CST entry covering "wheels, tyres, axles and wheel sets" rather than the residuary entry. The reasoning was that rims are an integral component of a wheel, or at least of a wheel set, and the specific entry was not displaced merely because rims were not separately named. In the absence of any competing specific entry, the term "wheel" was given its ordinary commercial meaning, and the interpretation favourable to the taxpayer was preferred where the construction was plausible. On that basis, the residuary entry was not applied.

---

---

Issues: Whether rims used in wheels of cycles and other vehicles fall within entry (xiv) of section 14(iv) of the Central Sales Tax Act covering "wheels, tyres, axles and wheel sets", so as to exclude resort to the residuary entry.

Analysis: The specific entry expressly covered axles, and the only controversy related to rims. The reasoning accepted rims as an integral component of a wheel or, at least, of a wheel set. In the absence of any competing specific entry, the word "wheel" in the relevant entry was given its ordinary commercial meaning, and a construction favourable to the taxpayer was preferred where the interpretation was at least plausible. On that approach, the residuary entry could not be applied.

Conclusion: Rims were held to fall within the scope of the specific entry and were not taxable under the residuary entry.

---