Common parlance test excludes television sets from "wireless reception instruments" under the sales tax entry.

Television sets, and their parts and accessories, were held not to fall within Entry 3 of the First Schedule to the A.P. General Sales Tax Act, 1957, for the period before 1 September 1976. The later insertion of the word "televisions" did not by itself establish that televisions were covered earlier, because an amendment may be clarificatory or by way of abundant caution. Applying the common parlance and commercial parlance tests, a television set was not ordinarily understood as a "wireless reception instrument and apparatus", but as equipment for reproducing pictures and sound transmitted by radio.

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Issues: Whether television sets and their parts and accessories were taxable under Entry 3 of the First Schedule to the A.P. General Sales Tax Act, 1957, prior to 1 September 1976, as wireless reception instruments and apparatus, or were taxable only as general goods.

Analysis: Entry 3, as it stood before amendment, covered wireless reception instruments and apparatus, radios, radio gramophones, electrical valves, accumulators, amplifiers, loud speakers, and spare parts and accessories thereof. The later insertion of the word "televisions" did not by itself conclusively show that televisions were taxable for the earlier period, because an amendment may be clarificatory or made by way of abundant caution. Applying the common parlance and commercial parlance tests, the expression "wireless reception instrument" would not ordinarily include a television set, since a television is understood in trade and common usage as an apparatus for reproducing pictures and sound transmitted by radio, not as a wireless set.

Conclusion: Television sets and their parts and accessories were not taxable under Entry 3 of the First Schedule prior to 1 September 1976 and were not includible in the expression "wireless reception instruments and apparatus".

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