Commercial and scientific meaning controls sales tax classification of formaldehyde; it falls under the chemical entry, not liquefied gas.

Formaldehyde was classified by applying its ordinary commercial and scientific meaning. Chemical references described it as a readily polymerisable gas commonly sold as an aqueous solution, while paraformaldehyde was identified as the solid polymerised form. On that basis, formaldehyde was held not to answer the description of a liquefied or solidified gas under item 106 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, and instead to fall within the chemical entry under item 138. The assessee's classification was accepted, and the higher-rate assessment based on item 106 was not sustained.

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Issues: Whether formaldehyde is a liquefied or solidified gas falling under item 106 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, or a chemical falling under item 138 of that Schedule.

Analysis: The classification turned on the ordinary meaning of formaldehyde. Reference was made to chemical dictionary descriptions showing formaldehyde as a readily polymerizable gas commercially sold as aqueous solution, and paraformaldehyde as its polymerized solid form. On that basis, the commodity was held not to be a liquefied or solidified gas for item 106. Instead, it was treated as a chemical properly falling within item 138 of the First Schedule.

Conclusion: Formaldehyde does not fall under item 106 and is taxable under item 138; the assessee's classification was accepted.

Final Conclusion: The revision failed, and the assessment at the higher rate based on item 106 was not sustained.

Ratio Decidendi: For sales tax classification, the entry applicable to a commodity must be determined by its ordinary commercial and scientific understanding, and where the substance is not shown to answer the description of the competing entry, it falls under the more appropriate residual or specific chemical entry.

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