Popular meaning test for goods classification treated leco as charcoal, securing exemption from sales tax as domestic-use charcoal.

Leco was treated as charcoal, not coal, for sales tax classification under the Karnataka Sales Tax Act, 1957. The Court applied the popular meaning test, holding that goods must be classified by the understanding of persons dealing in them rather than by scientific or technical analysis. An earlier decision treating leco as charcoal was treated as controlling, so the proposed levy based on classification as coal could not stand. The exemption for fire-wood or charcoal sold for domestic use was therefore available to the petitioners.

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Issues: Whether leco is to be treated as charcoal, and therefore covered by the exemption for fire-wood or charcoal sold for domestic use under the Karnataka Sales Tax Act, 1957, or as coal falling within the taxable declared goods entry.

Analysis: The classification of goods for taxation is to be determined by their popular meaning and the understanding of persons dealing in them, rather than by scientific or technical analysis. An earlier decision of the Court had proceeded on the basis that leco was charcoal, and that foundation was treated as controlling. In that view, the levy proposed by treating leco as coal could not be sustained, and the exemption applicable to charcoal sold for domestic use was available.

Conclusion: Leco was held to be charcoal, not coal, and the petitioners were entitled to the exemption.

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