Commercial identity of paper controls classification; filter paper falls within the broad sales tax entry.

Filter paper was treated as a recognised variety of paper within the broad expression "paper of all kinds" in entry 24(2) of Schedule C to the Bombay Sales Tax Act, 1959. The classification turned on the commodity's essential commercial identity in trade, supported by technical description and trade understanding, rather than its specialised use in filtration. The fact that it was not used for writing or printing did not narrow the wide statutory language, and the specific varieties listed in the entry did not limit the general words. Filter paper therefore fell within entry 24(2) and was excluded from the residuary entry.

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Issues: Whether filter paper falls within entry 24(2) of Schedule C to the Bombay Sales Tax Act, 1959 as "paper of all kinds" and is therefore outside the residuary entry in Schedule E.

Analysis: Entry 24(2) used the wide expression "paper of all kinds" and expressly included several non-writing varieties of paper such as sand paper, straw board, card board and duplex and triplex boards. The statutory language showed that the relevant inquiry was whether the commodity was a kind or variety of paper, not the use to which it was put. Filter paper was shown by trade nomenclature, technical description, samples and supporting material to be a recognised variety of paper. Its specialised use in filtration did not alter its essential character. The broad wording of the entry therefore could not be narrowed by reference to the specific varieties mentioned in item (1) or by the fact that the paper was not used for writing or printing.

Conclusion: Filter paper falls within entry 24(2) of Schedule C as paper of all kinds and is not covered by the residuary entry.

Ratio Decidendi: Where a taxing entry uses comprehensive language such as "paper of all kinds", the commodity is classified according to its essential commercial identity as understood in trade, and its particular end-use does not exclude it from the entry.

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