Common parlance test for stainless steel classification left safety razor blades in the unclassified tax category.

Safety razor blades were held not to qualify as stainless steel items for tax classification because, in common parlance, stainless steel denotes material that resists rusting, and the blades were found susceptible to rust and magnetic testing. In the absence of a statutory definition, the commercial understanding of the term governed. Relying on that approach and an earlier decision on similar blades, the court concluded that the goods fell within the unclassified category rather than the higher-taxed stainless steel category, and the revisional challenge failed.

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Issues: Whether safety razor blades manufactured by the assessee were classifiable as stainless steel items liable to tax at the higher rate, or as unclassified items liable to tax at the lower rate.

Analysis: The classification depended on the commercial understanding of stainless steel items. The finding recorded was that the blades were susceptible to rust and magnetic test, showing that they were not immune to rusting. In the absence of a statutory definition, the common parlance meaning of stainless steel was applied. On that basis, the blades could not be treated as stainless steel items. The earlier decision treating similar blades as unclassified items supported the same view.

Conclusion: The blades manufactured by the assessee were not stainless steel items but unclassified items, and the revisional challenge failed.

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