Common parlance test classifies dryer felts as textiles, confirming sales tax exemption under the Punjab sales tax schedule.

In taxing statutes, ordinary commercial meaning governs unless a contrary intention appears, so "textiles" is understood in common parlance as woven fabric rather than by a technical definition. Dryer felts manufactured from cotton and woollen yarn, with some synthetic yarn, by a weaving process on powerlooms in warp-and-woof pattern were treated as fabric; their use in paper-making machinery did not alter that character. The reference in the Customs Tariff Act to woven textile felts used in paper-making also supported classification as textile fabrics. On that basis, dryer felts fell within Item 30 of Schedule B of the Punjab General Sales Tax Act and were exempt from sales tax.

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Issues: Whether dryer felts manufactured by the assessee are "all varieties of cotton, woollen or silken textiles" within Item 30 of Schedule B of the Punjab General Sales Tax Act, 1948 and therefore exempt from sales tax.

Analysis: In a taxing statute, words of everyday use are to be understood in their popular or common parlance sense unless a contrary intention is shown. The expression "textiles" is not limited by a scientific or technical meaning; in ordinary commercial understanding it denotes a woven fabric. Dryer felts were found to be manufactured from cotton and woollen yarn, with some synthetic yarn, by a weaving process on powerlooms according to the warp and woof pattern. Their use in paper-making machinery did not change their character as fabric. The reference in the Customs Tariff Act, 1975 to woven textile felts commonly used in paper-making machinery also supported the view that such goods are treated as textile fabrics in ordinary trade parlance.

Conclusion: Dryer felts are textiles within Item 30 of Schedule B and are exempt from sales tax. The answer is in favour of the assessee and against the Revenue.

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