Common parlance classification test placed mafon gas under refrigeration material rather than general chemicals for sales tax.

Mafron gas was treated as refrigeration material for sales tax classification because it was mainly used in refrigerators and air-conditioners for cooling and was understood in the market in that way. The Court applied the common parlance and commercial understanding test, and also held that a specific tariff or notification entry prevails over a general entry. On that basis, the commodity was placed under the entry for refrigeration and air-conditioning plants, appliances and refrigeration materials rather than the general entry for chemicals, against the assessee.

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Issues: Whether mafron gas was classifiable as "all kinds of chemicals" or as "refrigeration material" for the purpose of sales tax.

Analysis: The commodity was found to be mainly used in refrigerators and air-conditioners for cooling and was understood in the market as a refrigeration material. The relevant notifications separately prescribed a lower rate for chemicals and a higher rate for refrigeration and air-conditioning plants, appliances, and refrigeration materials. The Court relied on the principle that classification must follow the common parlance and commercial understanding of the goods, and that a specific entry prevails over a general one. It also noted that similar gases had earlier been treated as refrigeration materials and that the Tribunal's factual finding was supported by the record.

Conclusion: Mafr on gas was held to fall under the specific entry for refrigeration material and not under the general entry for chemicals, against the assessee.

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