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Issues: Whether printed account books and registers were classifiable as printed materials under entry 97B of the First Schedule to the Kerala General Sales Tax Act, or as paper products under entry 97, or were exigible only as unclassified items at the general rate.
Analysis: The relevant entries treated paper and its products under entry 97 and printed materials other than journals and books meant for reading under entry 97B. The decisive consideration was the nature of the goods in trade and common understanding. Account books and registers containing substantial printing were not mere blank stationery; the printing was integral to their use and commercial identity. On that basis, they could not be treated as unclassified goods. Even if they were not brought within entry 97B, they still fell within entry 97 as paper products. The rate under either entry was the same.
Conclusion: Printed account books and registers were taxable at 8 per cent under entry 97B, or alternatively under entry 97, and not as unclassified items at 5 per cent.
Ratio Decidendi: For sales tax classification, goods must be placed according to their commercial identity and common understanding; where printing is integral to the character and use of account books and registers, they are not unclassified stationery but fall within the relevant entries for printed materials or paper products.