Popular and trade parlance test classifies bathroom fittings as sanitary fittings, not general brass goods.

Chromium plated brass fittings such as taps, showers, bibcocks, pillar cocks and stopcocks were classified in their popular and trade parlance as "sanitary fittings" when they were chiefly understood and used in bathrooms, lavatories and toilets. The Court applied the common commercial meaning test, relying on the nature of the goods, predominant use, trade understanding and the petitioner's own brochure, and distinguished authorities concerning pipes, tanks and sinks because those goods were not shown to be sanitary fittings in ordinary parlance. The goods therefore fell under entry 3 of Part S of the Second Schedule to the Karnataka Sales Tax Act, 1957, and not under the brass goods entry.

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Issues: Whether chromium plated brass fittings such as taps, showers, bibcocks, pillar cocks and stopcocks are "sanitary fittings" falling under entry 3 of Part S of the Second Schedule to the Karnataka Sales Tax Act, 1957, or articles made of brass under entry 8(iii) of Part B of the Second Schedule.

Analysis: The expression "sanitary fittings" was construed in its popular and trade parlance meaning. Items used mainly in bathrooms, lavatories and toilets, even if also capable of incidental use elsewhere, remain sanitary fittings if that is their main commercial understanding. The Court referred to the nature of the goods, their predominant use, the common understanding in trade circles, and the petitioner's own brochure describing the items as sanitary fittings. The contrary authorities dealing with pipes, tanks and sinks were distinguished because those goods were not shown to be sanitary fittings in their ordinary commercial sense. The governing test was whether the goods are known and sold as sanitary fittings in common parlance and whether their principal use is in bathrooms and allied sanitary areas.

Conclusion: The goods were held to be sanitary fittings under entry 3 of Part S and not articles made of brass under entry 8(iii) of Part B. The revision petitions failed and the Revenue's classification was upheld.

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