Common parlance test for bamboo products: agarbathi sticks qualify for sales tax exemption as finished products.

Bamboo agarbathi sticks are manufactured from bamboo splits by human labour and are treated in common parlance as bamboo products, not as the raw bamboo splits themselves. The exemption notification under section 8-A of the Karnataka Sales Tax Act, 1957 was read in its ordinary and commercial sense, so the departmental circular adopting a narrow technical meaning was not accepted. On that basis, the sticks qualified for exemption as bamboo products and were not liable to sales tax on the sale turnover under section 5(3)(a) of the Act.

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Issues: Whether bamboo agarbathi sticks are bamboo products entitled to exemption under the notification issued under section 8-A of the Karnataka Sales Tax Act, 1957, or whether they are to be treated as bamboo splits exigible to tax.

Analysis: The expression used in the exemption notification was understood in its ordinary and commercial sense. Bamboo agarbathi sticks are manufactured from bamboo splits by human effort and labour, and therefore are not the same as bamboo splits. A split bamboo remains bamboo, but the finished agarbathi sticks are products obtained from bamboo and not the raw material itself. The departmental circular treating them as bamboo splits adopted a narrow and technical meaning inconsistent with common parlance and the purpose of the exemption notification. The reasoning accorded with the meaning of "product" as explained in the cited Supreme Court decision.

Conclusion: Bamboo agarbathi sticks are bamboo products and are entitled to exemption under the notification issued under section 8-A of the Karnataka Sales Tax Act, 1957. They are not liable to sales tax on the sale turnover under section 5(3)(a) of the Act.

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