Common parlance classification excludes chewing gum and bubblegum from lozenges, leaving them taxable under the residuary entry.

Chewing gum and bubblegum are classified in sales tax law by their common parlance identity, not by technical or scientific distinctions. The MPHC held that these products have ingredients, characteristics, and consumer recognition distinct from lozenges, so they do not fall within the specific taxing entry for lozenges. The court also rejected application of noscitur a sociis and ejusdem generis to expand the entry to cover them. They are therefore taxable under the residuary entry, and the assessment and revisional orders were set aside to that extent with reassessment directed accordingly.

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Issues: Whether chewing gum and bubblegum are classifiable as "lozenges" for the purpose of taxation under the M.P. Commercial Tax Act, 1994, or whether they fall under the residuary entry.

Analysis: Classification under sales tax legislation must be made according to the meaning of the goods in common parlance and not by technical or scientific distinctions. Chewing gum and bubblegum have distinct ingredients, characteristics, use, and commercial identity from lozenges. A customer asking for chewing gum or bubblegum would not ordinarily be supplied lozenges. The entries covering lozenges, read in their context, do not include these goods, and the doctrine of noscitur a sociis or ejusdem generis does not bring them within the specific entry. The earlier Full Bench view of the appellate board, as well as the Supreme Court's approach to common parlance classification, supported treating these goods as different from the confectionery items expressly named in the taxing entry.

Conclusion: Chewing gum and bubblegum are not covered by the entry for lozenges and are taxable under the residuary entry. The assessment and revisional orders were set aside to that extent, and reassessment was directed accordingly.

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