Commercial meaning of manganese includes ferro manganese, preserving single-point taxation under the sales tax schedule.

Ferro manganese was held to fall within the commercial expression "manganese" in Entry 1 of the Second Schedule to the Andhra Pradesh General Sales Tax Act. The Court applied a commercial, not scientific, interpretation because the Act used a single-point taxation scheme for specified goods and the entry expressly included manganese ore. As ferro manganese is a commercially recognised form of manganese used in the iron and steel industry, excluding it would defeat the legislative intent behind the schedule. The assessees were therefore not liable under the general charging provision.

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Issues: Whether ferro manganese falls within the expression "manganese" in Entry 1 of the Second Schedule to the Andhra Pradesh General Sales Tax Act, so as to be taxable only at the last point of purchase and not under the general charging provision.

Analysis: The expression in the schedule had to be understood in its commercial sense and not in a narrow scientific or technical sense. The Act adopts a scheme of single-point taxation for specified goods, and the entry expressly includes manganese ore. The material placed before the Court showed that manganese is dealt with in trade only in different commercial forms, including manganese ore, ferro manganese and silico manganese, and that ferro manganese is one of the commercially recognised forms in which manganese is used in the iron and steel industry. In that setting, excluding ferro manganese from the entry would defeat the legislative intent underlying the schedule and the single-point levy.

Conclusion: Ferro manganese is covered by the expression "manganese" in Entry 1 of the Second Schedule, and the assessees were not liable under section 5(1) of the Act.

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