Common parlance test governs sales tax classification: steam is not a chemical and falls under the residuary entry.

Where a sales tax entry does not define a product, classification depends on its common or commercial parlance meaning rather than scientific or technical usage. Applying that test, steam was not shown to be treated as a chemical in ordinary trade or everyday understanding, despite dictionary material and expert opinions. Steam is ordinarily understood as water vapour or a by-product of water, so it did not fall within Notification Entry No. 233 of the Bombay Sales Tax Act, 1959. It was instead classifiable under the residuary Schedule Entry C-II-102.

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Issues: Whether steam is classifiable as a chemical under Notification Entry No. 233 of the Bombay Sales Tax Act, 1959, or falls under the residuary Schedule Entry C-II-102.

Analysis: In the absence of a statutory definition, an item used in a sales tax entry must be understood in common parlance or commercial parlance and not by its scientific or technical meaning. The assessee produced dictionary material and expert opinions, but there was no material showing that steam is treated as a chemical in common trade or everyday understanding. Steam is ordinarily understood as a form of water vapour or a by-product of water, and the common parlance test therefore governed the classification.

Conclusion: Steam is not a chemical for the purpose of Notification Entry No. 233 and is properly classifiable under Schedule Entry C-II-102. The questions referred were answered in favour of the Revenue and against the assessee.

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