Commercial parlance test governs classification of decorative clay tiles, which are outside the concessional roofing tiles entry.

An undefined taxing entry for "roofing tiles" is construed in its ordinary and commercial sense, with classification turning on the commodity's trade identity and end use rather than the manufacturing process or material. The schedule distinguishes roofing tiles from other tiles, so a concessional rate confined to roofing tiles cannot be extended to decorative tiles used for building decoration. Decorative clay tiles are therefore treated as falling under the residuary entry for other tiles, and the assessing authority's classification, as restored in revision, is supported on that basis.

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Issues: Whether the expression "roofing tiles" in Entry 8(iii) of Part T of the Second Schedule to the Karnataka Sales Tax Act, 1957 includes decorative tiles manufactured from clay, and whether such decorative tiles are liable only to the concessional rate applicable to roofing tiles.

Analysis: The expression "roofing tiles" was not defined in the Act, so its meaning had to be gathered from the ordinary and commercial sense in which the commodity is understood in trade. The classification of goods in a taxing schedule depends on the statutory entry and the commercial identity of the commodity, not merely on the manufacturing process or the material from which it is made. The schedule itself distinguished between roofing tiles and other tiles, and the lower rate was intended only for tiles used for roofing. Tiles used for decorative purposes in buildings could not be equated with tiles used exclusively for roofing, especially when the assessee itself maintained separate accounts for the two categories.

Conclusion: Decorative tiles are not covered by the expression "roofing tiles" and fall under the residuary entry for other tiles. The classification made by the assessing authority and restored in revision was correct.

Ratio Decidendi: Where a taxing entry uses an undefined commodity description, the commodity must be classified according to its common and commercial parlance meaning, and a concessional entry confined to a specific end use cannot be extended to goods used for a different purpose.

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