Trade parlance classification treated sandalwood oil as vegetable oil, not perfume, scent, or volatile oil.

Sandalwood oil was held not to fall within the entry for perfume or scent because, in ordinary trade parlance, it was sold only as an essential oil and required further processing before cosmetic use. It was also held not to be a volatile oil yielded by oil seeds, so it could not be classified under the corresponding second schedule entry. Applying ordinary commercial meaning and the form in which the goods were sold, the Court treated sandalwood oil as a vegetable oil and brought it within the relevant first schedule entry, setting aside the assessment classification in favour of the assessee.

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Issues: Whether sandalwood oil is classifiable as perfume or scent under item 51 of the First Schedule to the Madras General Sales Tax Act, 1959, as a volatile oil under serial No. 6(a) of the Second Schedule, or as vegetable oil under serial No. 20 of the First Schedule.

Analysis: Sandalwood oil was held not to be a volatile oil yielded by oil seeds, and therefore it could not fall under serial No. 6(a) of the Second Schedule. On the meaning of perfume or scent, the relevant entries were construed as referring to articles ready for cosmetic use in ordinary trade parlance. Sandalwood oil, as sold, was only an essential oil and required further processing before it could serve as a perfume or scent. The Court also held that it was a vegetable oil in the sense of a product of the vegetable kingdom and therefore answered serial No. 20 of the First Schedule.

Conclusion: Sandalwood oil was not taxable as perfume or scent under item 51 or as a volatile oil under serial No. 6(a), but fell within serial No. 20 as vegetable oil; the classification adopted by the assessing authority was set aside and the revision succeeded in favour of the assessee.

Final Conclusion: The assessment had to be revised by treating sandalwood oil as vegetable oil and not as perfume or scent, with the assessee obtaining the relief sought.

Ratio Decidendi: In construing a sales tax entry, the goods must be classified according to their ordinary trade meaning and commercial form as sold, and an item requiring further processing before it can serve the described purpose does not fall within a consumable or ready-to-use cosmetic entry.

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