Firewood classification for sales tax turns on common commercial identity, not the buyer's later use for pulp production.

Sales tax classification depends on the common commercial understanding of the commodity, not on the purchaser's special use. Bits of karuvel trees sold as fuel wood were described in the assessee's records as firewood and were commonly treated as such, so their later use for pulp production did not change their essential character. On that basis, the notification exempting firewood applied, and the disputed turnover was not liable to tax. The revisional assessment was therefore unsustainable. The core principle is that a commodity is identified for tax purposes by its commercial identity in the market, rather than by a downstream use chosen by the buyer.

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Issues: Whether the bits of karuvel trees sold by the assessee were firewood exempt from sales tax under the relevant government notification, or whether their use by the purchaser for pulp production took them outside that description.

Analysis: The decisive test was the commercial and common parlance understanding of the commodity, not the purchaser's special use. The assessee's documents described the goods as firewood, and the materials showed that what was sold was bits of karuvel trees with bark, commonly treated as fuel wood. The fact that the buyer used the goods for pulp production did not alter their essential character for tax classification. The notification exempted firewood, and the commodity in question fell within that description.

Conclusion: The disputed turnover of karuvel trees was not liable to tax as it was covered by the exemption for firewood. The revisional assessment was unsustainable and the assessee succeeded on the issue.

Ratio Decidendi: For sales tax classification, a commodity must be identified by its common commercial understanding, and its character is not changed merely because a purchaser uses it for a special or different purpose.

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