Common-parlance test for textiles excludes processed insulation sleevings treated as a distinct commercial commodity.

Insulation sleevings made from yarn and further braided, polished, dyed and varnished were held not to answer the common or commercial meaning of "textile" under entry 30 of Schedule B to the Punjab General Sales Tax Act, 1948 as applicable to Haryana. Applying the settled taxing-statute rule of popular parlance, the processing was treated as having converted the yarn-based material into a distinct commercial commodity. On that reasoning, the sleevings were outside the textile entry and not entitled to exemption.

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Issues: Whether insulation sleevings manufactured from yarn and subjected to braiding, polishing, dyeing and varnishing fall within entry 30 of Schedule B of the Punjab General Sales Tax Act, 1948 as applicable to Haryana.

Analysis: Entry 30 covered all varieties of cotton, woollen or silken textiles including rayon, artificial silk or nylon, and the question had to be decided according to the popular or common parlance meaning of "textile", as settled in taxing-statute interpretation. The manufacturing process showed that although yarn was the base material, the product underwent substantial processing into braided, polished, dyed and varnished sleevings, losing the character of yarn or textile as ordinarily understood by traders and consumers. Authorities dealing with sleevings and similar processed products supported the view that such finished articles are treated as distinct commercial commodities and not as textiles.

Conclusion: The sleevings do not fall within entry 30 of Schedule B and are not exempt as textiles; the question was answered in favour of the department and against the assessee.

Ratio Decidendi: In interpreting fiscal entries, words of everyday use must be understood in their common or commercial parlance, and a processed article ceases to be a textile if, in trade and ordinary understanding, it has become a distinct commercial commodity.

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