Commercial identity of cotton governs tax classification; surgical cotton falls within the specific cotton entry, not the residuary rate.

Surgical cotton was treated as falling within the ordinary commercial meaning of "all kinds of cotton" in the relevant notification, because the omission of the words "in its manufactured or unmanufactured state" did not narrow the entry and the commodity retained its essential identity as cotton. The words "that is to say" were not confined to raw cotton alone, and the entry was wide enough to include cotton waste as well. Surgical cotton was also not a pharmaceutical preparation, since it was dressing material rather than a preparation of medicinal drugs. A commodity covered by the specific cotton entry could not be assessed under the residuary rate.

---

---

Issues: Whether surgical cotton or absorbent cotton was taxable under the entry for cotton at 4% under the notification dated 27 June 1990, or whether it fell under the residuary rate or under the entry for pharmaceutical preparations at 6%.

Analysis: The term "cotton" in the relevant notifications was construed in its ordinary commercial sense. The omission of the words "in its manufactured or unmanufactured state" in the later notification was held not to alter the essential meaning of the entry, because the expression "all kinds of cotton" remained wide enough to include cotton that continued to retain its character as cotton even after manufacture. The Court further held that the words "that is to say" did not confine the entry to raw cotton alone, and the later notification also expanded the entry by including cotton waste. On the alternative contention, surgical cotton was found not to be a pharmaceutical preparation, since it was dressing material and not a preparation of medicinal drugs. As the commodity reasonably fell within the specific cotton entry, it could not be assessed under the residuary entry.

Conclusion: Surgical cotton was taxable under the cotton entry at 4% and not under the residuary rate or the pharmaceutical preparation entry.

Final Conclusion: The revision succeeded and the assessment was required to be modified accordingly, granting relief to the assessee.

Ratio Decidendi: Where a commodity retains its essential commercial identity as cotton, a taxing entry for "all kinds of cotton" will include it notwithstanding manufacture, and a commodity reasonably covered by a specific entry cannot be taxed under a residuary entry or an inapplicable general description.

---