Common and commercial parlance governs tariff classification of toilet soap as household soap under the excise schedule.

Toilet soap is classified in common and commercial parlance as household soap under Tariff Item 15(1), because tariff entries must be construed by the ordinary market meaning of the goods rather than by technical distinctions or departmental practice. The 1964 amendment displaced the earlier separate treatment of toilet soap, and the amended entry did not specifically place it in the residual category of other sorts. Contemporaneous executive understanding was given little weight where the amended provision was recent. Toilet soap therefore falls within Tariff Item 15(1) and not Tariff Item 15(2).

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Issues: Whether toilet soap was classifiable under Tariff Item 15(1) as household soap or under Tariff Item 15(2) as other sorts under the First Schedule to the Central Excises and Salt Act, 1944.

Analysis: The tariff entries had to be construed according to the language used and the meaning attached to the goods in common and commercial parlance. The earlier separate treatment of toilet soap was displaced by the 1964 amendment, and the amended entry did not specifically place toilet soap in the residual category of other sorts. In that setting, the decisive test was the popular understanding of the product as ordinarily bought and sold, not a narrow or technical distinction based on user preference or departmental practice. The Court also held that contemporaneous executive understanding carried little weight where the amended provision was of recent origin and the classification issue arose shortly after the amendment.

Conclusion: Toilet soap falls within Tariff Item 15(1) as household soap and not within Tariff Item 15(2) as other sorts.

Ratio Decidendi: In tariff classification, goods must be identified and construed according to their common and commercial parlance meaning, and where the statutory entry does not specifically place a product in a separate or residual category, it must be classified under the entry that best reflects its popular market understanding.

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