Common parlance test for paper products: printed material was held outside taxable paper products under sales tax law.

Printed matter supplied by a printer from his own stock was held not to be a "paper product" under item 42 of Schedule I of the Kerala General Sales Tax Act, 1963. Applying common parlance, the Court reasoned that "paper products" means articles made out of paper in ordinary commercial understanding, not every item to which paper has merely been subjected to printing or another process. Books, pamphlets, diaries and similar printed materials do not become paper products merely because they are printed on paper. The Tribunal's view that any processing of paper converts it into a taxable paper product was rejected, and the levy was held unsustainable.

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Issues: Whether printed material supplied by a printer on paper supplied from his own stock is a "paper product" falling within item 42 of Schedule I of the Kerala General Sales Tax Act, 1963 and therefore taxable.

Analysis: Paper, not being defined in the Act, must be understood in its common parlance sense. The expression "paper products" denotes something produced out of paper in the ordinary commercial understanding, and not every article to which paper has merely been subjected to printing or some other process. Printed matter, books, pamphlets, diaries, or similar material do not become products of paper merely because they are printed upon paper; the paper loses its utility as paper, but the resulting article is not ordinarily regarded as a product of paper. The Tribunal's approach that any process on paper necessarily converts it into a paper product was rejected.

Conclusion: The printed material supplied by the petitioner was neither paper nor a paper product and did not fall within item 42 of Schedule I. The levy was therefore unsustainable and the assessee succeeded.

Ratio Decidendi: For sales tax purposes, an article is taxable as a "paper product" only if, in common parlance, it is understood as a product made out of paper, not merely as paper on which printing or another process has been performed.

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