Common parlance meaning of "paper" covers printed packing wrappers, keeping them outside the residuary tax entry.

The term "paper" in a taxing entry, when left undefined, must be understood in its common parlance sense. On that basis, white printed wrappers used for packing cotton textile goods remained paper because they continued to perform a packing function and did not lose their character merely because they were printed for a specific use. A later amendment adding "printed wrappers of paper" was treated as indicating a lower tax rate for that category, not as excluding such wrappers from the earlier specific entry. The residuary entry applied only where no specific entry covered the goods, so the wrappers fell within the paper entry and not the residuary charge.

---

---

Issues: Whether white printed wrappers sold for packing cotton textile goods fell within the expression "paper" under entry 31 of Schedule II, Part A to the Gujarat Sales Tax Act, 1969, or were liable to be taxed under the residuary entry 13 of Schedule III.

Analysis: The expression "paper" in entry 31 was not specially defined and had therefore to be understood in its common parlance meaning. On that basis, paper included articles used for packing, and printed wrappers did not cease to be paper merely because they were printed for a particular use. The fact that a later amendment specifically added "printed wrappers of paper" in entry 12 was treated as indicating a lower rate of tax for that category, not as showing that such wrappers were outside the ambit of entry 31. The residuary entry could apply only when the goods did not fall within any specific entry, and here the goods were covered by the specific entry for paper.

Conclusion: White printed wrappers were covered by entry 31 of Schedule II, Part A as paper and were not assessable under the residuary entry 13 of Schedule III.

Ratio Decidendi: Where a taxing entry uses the word "paper" without special definition, the term must be construed in common parlance, and printed wrappers that continue to serve the packing function remain paper unless specifically excluded.

---