Common parlance classification rules place a stainless steel kitchen sink under stainless steel products, not sanitary fittings.

A stainless steel kitchen sink is classified by its common parlance meaning rather than by material alone. The Kerala General Sales Tax Act entries were construed on the scope of the competing descriptions: entry 125 covered stainless steel products, while entry 149 covered water supply and sanitary equipment and fittings. Because "water supply and sanitary fittings" was treated as a composite expression, sanitary fittings were confined to articles used in lavatories, urinals or bathrooms. A kitchen sink used mainly for washing vessels did not fall within that description, so it was held to be classifiable under entry 125 as a stainless steel product.

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Issues: Whether a stainless steel kitchen sink falls under entry 125 of the First Schedule to the Kerala General Sales Tax Act, 1963 as a stainless steel product, or under entry 149 as water supply and sanitary equipment and fittings.

Analysis: The classification had to be determined according to the common parlance meaning of the goods and the scope of the competing entries. Entry 125 covered stainless steel rods and sheets and stainless steel products, while entry 149 covered water supply and sanitary equipments and fittings. The expression "water supply and sanitary fittings" was treated as a single composite expression, and the words relating to water supply were understood in the light of the accompanying words "sanitary fittings". On that approach, sanitary fittings mean articles used in lavatories, urinals or bath rooms, and a kitchen sink used mainly for washing vessels does not answer that description merely because it is made of stainless steel.

Conclusion: A stainless steel kitchen sink is not classifiable under entry 149 as sanitary fittings and falls under entry 125 as a stainless steel product.

Ratio Decidendi: For sales tax classification, a commodity must be placed in the entry that answers its popular or common parlance meaning, and a composite entry such as "water supply and sanitary fittings" must be construed in the context of the associated words so that only articles meant for sanitary use in lavatories, urinals or bathrooms are covered.

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