Synthetic adhesive outside the "glue" entry where the notification used a narrow, specific commodity description.

The notification taxed specified goods by name, including "glue" at 12%, but the term was applied in its ordinary and narrower sense. A synthetic adhesive made from chemical compounds, such as falcofix-SH, could not be expanded into that specific entry where the notification did not use a broader expression like "adhesive". In the absence of evidence that the product fell within the common meaning of glue, it remained outside the scheduled commodity and was taxable only under the residuary rate.

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Issues: Whether 'falcofix-SH' falls within the entry 'glue' in Notification No. F. 5(22)FD/CT/70-7 dated 9th March, 1970 and is therefore taxable at 12% under section 5 of the Rajasthan Sales Tax Act, 1954, or is taxable only under the residuary rate.

Analysis: The notification specifically enumerated goods by nomenclature and included 'glue' at 12%. The material on record showed that 'falcofix-SH' was a synthetic adhesive manufactured from chemical compounds, whereas 'glue' was treated as a narrower term denoting an organic adhesive derived from natural materials. The Department led no evidence to show that the commodity could be brought within the ordinary meaning of 'glue'. Since the entry did not use a wider expression such as 'adhesive', the synthetic product could not be expanded into the specific scheduled commodity.

Conclusion: 'falcofix-SH' does not fall within the entry 'glue' and is not taxable at 12% under the notification.

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