Common parlance test excludes leather sheets made from waste cuttings from hides and skins classification.

Leather sheets made from waste leather cuttings were held not to fall within the notification entry for "hides and skins whether in raw or dressed state" because the manufacturing process crushed, refined, washed and bound the waste into a commercially distinct product, destroying the original fibrous structure and the identity of hide or skin. The phrase was treated as covering only successive stages of the same commodity, namely raw, cured, picked, tanned and dressed forms, and not a product that had lost its character as hide or skin. On common parlance, leather board or leather sheets were not understood as dressed hides or skins, so the classification claim failed.

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Issues: Whether leather sheets manufactured from waste leather cuttings fell within entry 10 of the notification as "hides and skins whether in raw or dressed state".

Analysis: The commodity was produced by crushing waste leather cuttings into powder, screening and refining the powder, removing hard particles, washing away dust, dirt, resins, greases and oils, and then binding the material with latex before drying it into sheets. This process destroyed the original fibrous structure and changed the material into a commercially distinct product. The expression "hides and skins in the raw or dressed state" was held to cover raw, cured, picked, tanned and dressed stages of the same commodity, but not a product whose identity as hide or skin had been lost. On the evidence, leather board or leather sheets were not understood in common parlance as dressed hides or skins.

Conclusion: Leather sheets manufactured by the assessee did not fall within entry 10 as hides and skins in raw or dressed state, and the answer was against the assessee.

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