Common parlance test excludes prawns from a fish tax exemption, with later clarificatory amendment confirming intent.

A sales tax exemption entry for "fish" was construed in common and commercial parlance, and prawns were held to be a distinct commodity. The court treated the later amendment expressly excluding prawns and lobsters as clarificatory of the original notification, indicating that prawns were never intended to fall within the exemption. The existence of a separate taxable entry for prawns supported that interpretation, and the later restoration of the original wording did not change the result. The assessee could not rely on the 1989 exemption for the earlier period, so the exemption benefit was denied.

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Issues: Whether prawns fall within the exemption for "fish" under the sales tax exemption notification, and whether the subsequent amendments to the notification showed that prawns were intended to be included within that exemption.

Analysis: The expression "fish" in the exemption entry had to be understood in common parlance and commercial parlance. On that basis, fish and prawns were distinct commodities, and a purchaser asking for fish would not ordinarily be understood as asking for prawns. The later amendment expressly excluding prawns and lobsters was treated as clarificatory of the original entry, showing that prawns were never within the intended scope of the exemption. The later restoration of the original wording did not alter that conclusion. The separate taxable entry for prawns also supported the view that the commodity was not covered by the fish exemption. The express exemption granted in 1989 could not assist the assessee for the earlier period in question.

Conclusion: Prawns were not covered by the exemption for fish, and the assessee was not entitled to the benefit of the exemption notification.

Ratio Decidendi: In construing a sales tax exemption entry, a commodity must be understood in its common and commercial parlance meaning, and a later clarificatory amendment may be used to explain the original legislative intent.

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