Generic paper entry covers tissue products in substance, excluding residuary taxation under the Haryana VAT schedule.

Generic taxing entries cover all forms of a named commodity that retain its essential character, and the residuary entry applies only when the goods cannot reasonably fit within the specific entry. Tissue paper, napkins, toilet paper rolls, kitchen wipes and facial tissues were held to remain paper in substance under the broad expression "paper" in Entry 57 of Schedule C of the Haryana Value Added Tax Act, 2003. The end-use test was rejected because the entry contained no user-based qualification or exclusion. These products therefore fall within Entry 57 and are not taxable under the residuary entry.

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Issues: Whether tissue paper and allied products such as napkins, toilet paper rolls, kitchen wipes and facial tissues fall within Entry 57 of Schedule C of the Haryana Value Added Tax Act, 2003 as "paper, paper board and newsprint", or are liable to tax under the residuary entry.

Analysis: Entry 57 uses the generic expression "paper" without any express inclusion, exclusion, or user-based qualification. A generic taxing entry ordinarily covers all kinds of goods that retain the essential characteristics of the commodity named in the entry. The materials in question, though used for different purposes and of different strength, remain paper in substance. There was no competing specific entry excluding them, and the residuary entry can be invoked only when the goods cannot be brought within the specific entry even on liberal construction. The end-use test was held inapplicable because the statutory entry itself did not make use determinative.

Conclusion: Tissue paper and its allied forms fall within Entry 57 of Schedule C of the Haryana Value Added Tax Act, 2003, and are not taxable under the residuary entry.

Ratio Decidendi: Where a taxing entry names a commodity in generic terms without qualifying it by use or exclusion, all forms retaining its essential character are covered by that entry and the residuary entry cannot be used.

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