Tariff classification of heat treatment salt turns on trade parlance and essential character, placing it within the chemical entry.

Heat treatment salt was treated as a chemical for sales tax classification because its essential properties, commercial identity and common trade understanding showed it to be a cyanide-containing liquid used to produce a chemical effect on metal. The court applied the principle that tariff classification depends on the general character of the commodity in trade parlance and not merely on the purchaser's end-use. On that basis, the product fell within entry 138 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, rather than the general provision under section 3(1), and was taxable at 8 per cent. The revisions were dismissed.

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Issues: Whether heat treatment salts are classifiable as "dyes and chemicals" under entry 138 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, or fall under section 3(1) of that Act.

Analysis: The product was found to be a cyanide-containing liquid used for carburising steel and producing a chemical effect on metal. Its essential properties, commercial understanding, and the nature of its use showed that it answers the description of a chemical in common trade parlance. Classification for sales tax purposes depends on the general character and commercial identity of the commodity, not merely on the use by a particular purchaser.

Conclusion: Heat treatment salt was held to be a chemical falling under entry 138 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, and taxable at 8 per cent. The revisions were dismissed.

Ratio Decidendi: For tariff classification, a commodity must be identified by its general commercial and popular understanding and by its essential properties, and not solely by the end-use to which it is put.

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