Common parlance test excludes sewage pumps from the water-pump GST entry under the rate notification.

Pumps primarily designed for handling sewage or waste were held not to fall within Sl. No. 192 of Schedule II of Notification No. 1/2017-Central Tax (Rate), which covers pumps for handling water at 12% GST. The undefined term "water" was read in its common parlance sense, and the notification's separate reference to "sewage" and "water" showed that they were intended to denote different goods. The Authority also found that sewage or waste pumps are commercially distinct from pumps meant for clear or raw water, so the water entry could not be expanded to include them.

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Issues: Whether pumps primarily designed for handling sewage or waste are covered by Sl. No. 192 of Schedule II of Notification No. 1/2017-Central Tax (Rate), dated 28.06.2017, so as to qualify for GST at 12%.

Analysis: The term "water" in the tariff entry was construed in its popular and common parlance sense because it was not specifically defined in the notification. Applying the common parlance test, the Authority noted that the same notification separately referred to "sewage" and "water" in another entry, showing that the two expressions were intended to denote different goods. The entry for pumps primarily designed for handling water was therefore held to cover clear or raw water, not sewage or waste. The Authority also held that pumps for sewage or waste are commercially distinct from pumps for handling water.

Conclusion: Pumps for sewage or waste are not covered by Sl. No. 192 of Schedule II of Notification No. 1/2017-Central Tax (Rate), dated 28.06.2017, and are not eligible for GST at 12%.

Ratio Decidendi: Where a tariff entry uses an undefined expression in a taxing notification, it must be understood in common parlance, and a separately used expression in the same notification cannot be read into that entry.

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