Trade understanding governs classification of goods under fiscal entries; dictionary meaning alone is insufficient without proper factual inquiry.

Classification of multipin connectors under a fiscal entry depends on the trade or commercial understanding of the goods among persons conversant with that trade, not on dictionary meaning alone. The Tribunal had relied chiefly on dictionary meaning and the identity of purchasers without a proper factual inquiry into how the goods were understood in the market. Because classification was a mixed question of law and fact, the fact-finding authority was required to examine relevant evidence, including trade testimony, before selecting the applicable entry. The finding that the goods were telecommunication apparatus could not be sustained on the existing material, and fresh factual determination was required.

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Issues: Whether multipin connectors manufactured and sold by the assessee fall under entry 132 of the First Schedule to the Kerala General Sales Tax Act as telecommunication apparatus, or under entry 130 as electrical goods and allied articles.

Analysis: The proper test for classifying goods under a fiscal entry is the sense in which persons conversant with the relevant trade understand the commodity. Where the entry relates to a particular business or trade, commercial and trade understanding is more relevant than a dictionary meaning alone. The Tribunal had relied mainly on dictionary meaning and the identity of the purchasers, but no proper factual inquiry was made into how the goods were understood in the trade. The classification of the goods was a mixed question of law and fact, and the final fact-finding authority was required to examine relevant evidence, including testimony from persons connected with the trade, before deciding the applicable entry.

Conclusion: The Tribunal's finding that the goods were telecommunication apparatus could not be sustained on the material before it, and the matter required fresh factual determination by the Tribunal.

Ratio Decidendi: Classification of goods under a fiscal entry must be determined on the basis of their trade or commercial understanding, after proper factual inquiry by the fact-finding authority, and not by dictionary meaning alone.

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