Common parlance test governs exemption notifications: chicory seeds were not treated as vegetable seeds for sales tax relief.

Chicory seeds were not covered by the expression "vegetable seeds" in the sales tax exemption notification under the Tamil Nadu General Sales Tax Act, because exemption entries must be strictly construed and commodity descriptions given their common or commercial meaning, not their botanical sense. On that test, chicory seeds were not regarded in ordinary trade or household understanding as vegetable seeds, so the exemption did not apply. Botanical links to vegetation, or differing treatment in foreign markets, could not enlarge the scope of the notification. The Tribunal had therefore misdirected itself in extending the exemption.

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Issues: Whether chicory seeds were covered by the expression "vegetable seeds" in the exemption notification issued under section 17 of the Tamil Nadu General Sales Tax Act, 1959, so as to qualify for sales tax exemption.

Analysis: The expression "vegetable seeds" had to be construed in its common or popular sense, as understood by persons dealing in such goods, and not in its botanical sense. Exemption notifications are to be strictly construed. Applying that test, chicory seeds could not be treated as vegetable seeds in ordinary commercial or household understanding. The fact that chicory might have some botanical connection with vegetation, or that it may be treated differently in foreign markets, was irrelevant to the construction of the notification. The Tribunal had therefore misdirected itself in extending the exemption.

Conclusion: Chicory seeds were not eligible for exemption as "vegetable seeds" under the notification.

Ratio Decidendi: In construing exemption entries in sales tax law, words describing commodities must be given their common parlance or commercial meaning, and an exemption notification must be strictly construed; botanical or technical meaning cannot enlarge the exemption.

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