Common parlance test treats gypsum sold for agricultural use as a tax-free fertilizer entry.

Gypsum sold to farmers for application to the soil was treated as a fertilizer under Entry No. 27 of Schedule B of the Haryana General Sales Tax Act, 1973. Because the Act did not define "fertilizer" or "gypsum," the meaning was derived from dictionaries, agricultural literature, and common parlance. The decisive factor was gypsum's practical use as a soil amendment and plant nutrient to correct sulphur deficiency and improve soil fertility, not its possible industrial uses. On that basis, gypsum sold to farmers or co-operative societies for agricultural use fell within the entry and was tax-free, though not every form of gypsum would automatically qualify.

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Issues: Whether gypsum sold to farmers is fertilizer within Entry No. 27 of Schedule B of the Haryana General Sales Tax Act, 1973.

Analysis: The Act did not define fertilizer or gypsum, so the meaning was gathered from dictionaries, agricultural literature, and practical use. The material showed that gypsum contains calcium and sulphate, is used to correct sulphur deficiency and improve soil fertility, and is sold to farmers for application to the soil. The determining question was not whether gypsum may also have industrial uses, but whether gypsum sold in this case was understood and used as a fertilizer in common parlance. On that basis, gypsum used by farmers as a soil amendment and plant nutrient was treated as a mineral fertilizer, although all gypsum would not automatically fall within the entry.

Conclusion: Gypsum sold to farmers or co-operative societies for use as a fertilizer falls within Entry No. 27 of Schedule B and is tax-free; the question was answered in the affirmative, in favour of the assessee.

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