Common parlance test governs classification of an LPG stove; essential components, not stainless steel body, determine the tax entry.

Classification of goods under a taxing statute turns on common parlance, functional identity, and the predominant component of the article. An LPG stove could not be treated as a stainless steel product merely because its body was made of stainless steel, since the burner and fittings were the essential parts and the steel body was only accessory and cosmetic in character. On that basis, the stove fell under the specific entry for metal products rather than the stainless steel entry, and the revenue's classification was held to be incorrect.

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Issues: Whether "L.P.G. stove" was classifiable under the entry for stainless steel products or under the residuary entry for metal products under the Kerala General Sales Tax Act, 1963.

Analysis: Classification of goods in a taxing statute depends on the manner in which the article is understood in common parlance by dealers and consumers, and the functional identity of the product is a relevant guide. The predominant component and the commercial identity of the article are material considerations. On the facts, the burner and other fittings were the essential parts of the stove, while the stainless steel body was only an accessory providing convenience and appearance. A stove could not, in commercial understanding, be treated as a stainless steel product merely because one component was stainless steel.

Conclusion: The appropriate entry was Sl. No. 119 and not Sl. No. 182, and the classification adopted by the revenue authorities was incorrect.

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