Commercial parlance test separates tamarind seed from tamarind seed dhal for sales tax classification.

Under sales tax classification, two goods are treated as the same commodity only if they are understood in commercial parlance as one and retain the original article's essential identity after processing. Minimal processing does not necessarily create a new taxable item, but where roasting, dehusking, or conversion materially alters the commodity's character and value, the processed product is commercially distinct. On the stated facts, tamarind seed and tamarind seed dhal/kernel were held to be different commodities, and tax on tamarind seed dhal was treated as valid.

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Issues: Whether tamarind seed and tamarind seed dhal are the same commodity for sales tax purposes despite roasting and dehusking.

Analysis: In determining whether two articles are the same commodity under a taxing statute, the primary test is whether they are understood as one and the same in commercial parlance. Where processing is only minimal and the original commodity retains its essential attributes, the processed article may still be treated as the same commodity. On the facts, the use of the two articles was not shown to be identical, and the conversion of tamarind seed into dhal/kernel was treated as having altered its essential character and value.

Conclusion: Tamarind seed and tamarind seed dhal are different commodities, and the levy of tax on tamarind seed dhal is valid.

Ratio Decidendi: For sales tax classification, the decisive test is commercial parlance and retention of the original commodity's essential identity after processing; if the processed article is commercially distinct, it is a separate taxable commodity.

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