Commercial parlance test governs tax classification of mosquito repellent coil; it is treated as a repellent, not an insecticide.

Classification of mosquito repellent coil under tax entries depends on its common and commercial understanding, not on technical or scientific composition. The product was treated in the market as a mosquito repellent, not as a mosquito killer, and the reasoning applied to similar repellent products supported that view. The presence of insecticidal ingredients or registration material did not alter its essential commercial identity. It was therefore not classifiable as pesticides or insecticides, and the Tribunal's contrary view was unsustainable.

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Issues: Whether mosquito repellent coil (kachhuwa chap agarbatti) is classifiable as pesticides and insecticides for tax purposes.

Analysis: Classification in taxing entries is governed by the meaning understood in common or commercial parlance and not by technical or scientific understanding. The product was shown to be used as a mosquito repellent, not as a mosquito killer, and the reasoning adopted for mosquito repellent mats and similar products supported that such goods are understood in the market as repellents rather than insecticides. The mere presence of insecticidal ingredients or related registration material did not change the essential commercial identity of the product.

Conclusion: The product is not classifiable as pesticides or insecticides and the Tribunal's contrary view was unsustainable.

Ratio Decidendi: For classification under taxing statutes, the decisive test is the popular or commercial meaning of the product as understood by users and dealers, and a mosquito repellent remains a repellent unless it is shown to be treated in trade as an insecticide or pesticide.

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