Common parlance test for paper products excludes printed matter merely because it has been printed on paper.

Printed material prepared by a printer on paper supplied by him is not treated as a "paper product" for sales tax purposes merely because printing has been done on it. The Kerala High Court applied the ordinary commercial or common parlance test to the entry "paper" in Schedule I, holding that printing alone does not convert paper into a different commodity or into a product made out of paper. On that reasoning, books, pamphlets, records and similar printed matter are not ordinarily understood as paper products unless the finished article is commercially regarded as such. The disputed turnover was therefore outside item 42.

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Issues: Whether printed material prepared by a printer on paper supplied by him, and delivered to customers after printing, is a "paper product" taxable under item 42 of Schedule I of the Kerala General Sales Tax Act, 1963.

Analysis: The expression "paper" in the sales tax entry was to be understood in its ordinary commercial sense and not in any extended or special meaning. The Court held that mere printing on paper does not, by itself, convert paper into a different commodity or into a product of paper. Printed matter such as books, pamphlets, records, or similar material is not ordinarily regarded in common parlance as a paper product merely because printing has been done on it. The decisive consideration was whether the finished article, as understood by persons dealing with the subject, is a product made out of paper. On that test, the printed material supplied by the printer did not cease to be paper, nor did it become a paper product.

Conclusion: The printed material was not a paper product and did not fall within item 42 of Schedule I; the levy could not be sustained against the assessee.

Final Conclusion: The revision succeeded, the assessment was set aside, and the assessee was held not liable to sales tax on the disputed turnover.

Ratio Decidendi: Printed matter produced by a printer on paper supplied by him does not become a "paper product" for sales tax purposes unless, in common parlance, the finished article is understood as a product of paper rather than as paper merely printed upon.

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