Commercial parlance governs tax classification of goods; mosquito repellent mats were treated as unclassified, not insecticide.

Classification of goods for tax purposes turns on common or commercial parlance rather than a purely technical or scientific description. A product's trade understanding, manufacturer's certificate, and treatment in earlier decisions on similar goods may guide classification. On that basis, a commodity containing an insecticidal ingredient is not necessarily an insecticide if its accepted commercial identity is a mosquito repellent. 'Good Night Mats' was accordingly treated as a mosquito repellent and not as an insecticide, and it was liable to tax as an unclassified item.

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Issues: Whether "Good Night Mats" is taxable as an insecticide or as a mosquito repellent and, if not falling under a specific entry, as an unclassified item.

Analysis: Classification of goods for tax purposes must be determined by the understanding of the product in common or commercial parlance and not by a merely technical or scientific description. The product in question was considered in the light of its trade understanding, the manufacturer's certificate, and the approach adopted in earlier decisions on similar mosquito-repellent products. The fact that the commodity contained an insecticidal ingredient did not, by itself, make it an insecticide for tax classification purposes when its accepted commercial identity was that of a mosquito repellent.

Conclusion: "Good Night Mats" is not an insecticide. It is a mosquito repellent and is liable to be taxed as an unclassified item.

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