Common parlance classification of woven fabric as textile prevailed, making the machinery-accessory tax clarification unsustainable.

Damping cloth was classified as textile on the basis of its ordinary or popular meaning, rather than any technical description, and this attracted exemption under the Tamil Nadu General Sales Tax Act, 1959. Goods made of woven fabric or threads remain textiles in common parlance even if used in an industrial process, so the fact that damping cloth functioned as a component or accessory of an offset machine did not change its character. The clarification treating it as a taxable machinery accessory was therefore inconsistent with the settled classification principle and was quashed.

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Issues: Whether damping cloth is classifiable as textile and therefore entitled to exemption under the Tamil Nadu General Sales Tax Act, 1959, and whether the clarification treating it as a taxable machinery accessory was sustainable.

Analysis: The classification issue was governed by the ordinary or popular meaning of the word "textiles" and not by any technical description. Prior decisions had held that goods made from threads or woven fabric, though used in industrial processes, may still fall within the expression "textiles" if they are understood in common parlance as cloth or woven fabric. Applying that approach, damping cloth was found to be no different in substance from cloth used for garments and merely tubular in shape. The earlier clarification treating it as a vital component or accessory of an offset machine was therefore inconsistent with the settled legal position.

Conclusion: Damping cloth was held to be textile and the impugned clarification taxing it was unsustainable.

Final Conclusion: The assessee succeeded, and the clarification was quashed.

Ratio Decidendi: Goods made of woven fabric or threads are to be classified as textiles according to their common parlance understanding, and an industrial use as an accessory or component does not by itself take them out of that category.

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