Common parlance test governs sales tax classification of nylon zip fasteners, excluding them from plastic articles.

Nylon zip and nylon zip fastener were held not to be plastic articles under entry 145 of the Tamil Nadu General Sales Tax Act, 1959. The court applied the common parlance test and found that nylon goods are commercially understood as distinct from plastic articles, even if nylon shares a source material with plastic or contains minor additional materials such as cloth or metal. The revisional authority's classification as plastic articles was therefore erroneous, and the goods were liable to multi-point levy rather than single-point levy under that entry.

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Issues: Whether nylon zip and nylon zip fastener are to be treated as plastic articles falling under entry 145 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, or as separate commercial commodities liable to multi-point levy.

Analysis: The decisive test applied was the common parlance understanding of the goods in the market. Though nylon and plastic may share a common source material, nylon goods are commercially understood differently from plastic goods. The reasoning followed the view that articles made of nylon are distinct from plastic articles, and that the mere presence of minor additional materials such as cloth or metal does not alter their essential commercial identity. On that basis, the classification adopted by the revisional authority as a plastic article was held to be erroneous.

Conclusion: Nylon zip and nylon zip fastener are not plastic articles under entry 145, and the assessee was entitled to be taxed on the basis of multi-point levy rather than single-point levy under that entry.

Ratio Decidendi: Classification of a for sales tax purposes must be determined by its ordinary commercial or popular understanding, and a product is not to be treated as a plastic article merely because it contains nylon or other plastic-derived material.

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