Common parlance and principal use govern classification of slotted angles and panels as furniture parts over general iron and steel entry.

Sales tax classification depends on the ordinary commercial meaning of the goods and their principal use. Slotted angles and panels sold in unassembled form were treated as furniture or parts thereof made of iron or steel because they are normally used to make furniture and racks, and the fact that they may also have other uses did not change their main character. A specific entry for furniture therefore prevailed over the general iron and steel entry, placing the goods within the furniture classification under entry 145 of the Kerala General Sales Tax Act, 1963.

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Issues: Whether slotted angles and panels manufactured and sold in unassembled form fall within entry 145 of the First Schedule to the Kerala General Sales Tax Act, 1963 as furniture or parts thereof made of iron or steel, or under the general iron and steel entry 45.

Analysis: Classification under the sales tax schedule was held to depend on the ordinary and commercial meaning of the goods and on their main or normal use. The amended form of entry 145 expressly covered furniture or parts thereof made of iron or steel, and the earlier form was also treated as wide enough to include slotted angles and panels, since they are normally used to make furniture and racks and are sold in unassembled form for convenience. The possibility of some other use did not alter their principal character for tax classification. As the goods fell within the specific furniture entry, they could not be shifted to the general iron and steel entry.

Conclusion: Slotted angles and panels are classifiable under entry 145 of the First Schedule to the Kerala General Sales Tax Act, 1963 and taxable at 12 per cent, not under entry 45.

Final Conclusion: The levy of tax at the higher rate on slotted angles and panels was sustained, and the Revenue succeeded on the substantive classification issue.

Ratio Decidendi: For sales tax classification, goods are to be identified by their common parlance character and principal use, and where a specific entry applies, it prevails over a general entry even if the goods may also admit of some other use.

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