Common parlance test excludes specially processed ammonia and ferro paper from the paper entry under sales tax notification.

Chemically coated and specially processed ammonia paper and ferro paper were considered in the context of whether they fell within the sales tax entry for "paper other than hand made paper" under the U.P. Sales Tax Act notification. The controlling approach was the common parlance test: paper must be understood by its ordinary commercial meaning and by the uses ordinarily associated with paper. Because these goods were used only for obtaining prints and sketches of site plans, and not for printing, writing, packing, or other ordinary paper uses, they were treated as outside the entry and not taxable as paper of that description.

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Issues: Whether ammonia paper and ferro paper fall within the entry "paper other than hand made paper" in Notification No. ST-3124/X-1012(4)-1965 dated July 1, 1966 issued under the U.P. Sales Tax Act, 1948.

Analysis: The goods were chemically coated and specially processed paper used only for obtaining prints and sketches of site plans. They were not used for printing, writing, packing, or other ordinary purposes associated with paper as commonly understood. The controlling approach was the popular or common parlance meaning of the word "paper", and the goods were held to be outside that meaning. The reasoning was consistent with the treatment of similarly processed paper products in prior sales tax classification cases.

Conclusion: Ammonia paper and ferro paper do not fall within the entry "paper other than hand made paper" and are not taxable under the notification as paper of that description.

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