Common parlance test for oil seeds excludes coriander, ajwan and sompu treated as spices, not taxable as oil seeds.

'Oil seeds' in item 3 of Schedule IV of the Andhra Pradesh General Sales Tax Act was interpreted according to common parlance and legislative intent, not by the mere scientific possibility of extracting oil from any seed. On the evidence, coriander, ajwan and sompu were treated and sold as spices, their oil content was negligible, and there was no commercial or industrial recognition of them as oil seeds. They were therefore held not to fall within the statutory definition, and sales tax on their purchase turnover was not sustainable against the assessee.

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Issues: Whether coriander, ajwan and sompu fall within the definition of oil seeds under item 3 of Schedule IV of the Andhra Pradesh General Sales Tax Act.

Analysis: The expression "oil seeds" was construed in the sense understood in common parlance and in legislative contemplation, not by the mere possibility that oil may be scientifically extracted from any seed. The evidence showed that coriander, ajwan and sompu were known and used as spices, that the oil content was negligible, and that there was no material to show any commercial or industrial extraction or market recognition of these commodities as oil seeds.

Conclusion: The commodities were not oil seeds within item 3 of Schedule IV, and the assessment to sales tax on their purchase turnover was not sustainable in favour of the assessee.

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