Trade usage governs classification of plastic suit cases as plastic articles, not general goods, under sales tax law.

Plastic injection-moulded suit cases were treated as plastic articles for sales tax classification because their predominant composition, trade description, export classification and commercial understanding showed them to be regarded in commerce as plastic goods. The Court rejected any universal test based only on the value of constituent materials and preferred common parlance and trade usage for this classification dispute. It also noted that the later creation of a specific entry for suit cases from 1 July 1985 indicated that no separate entry existed during the earlier period. The suit cases fell within Entry 113 of Schedule I and were not taxable as general goods under Section 5(1); the exemption order was restored.

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Issues: Whether plastic injection-moulded suit cases fell within Entry 113 of Schedule I to the Andhra Pradesh General Sales Tax Act as plastic articles for assessment year 1981-82, and whether they were taxable as general goods under Section 5(1) of the Act.

Analysis: The suit cases were manufactured predominantly from plastic by injection moulding, though fitted with steel bands, locks and other ancillary parts. The surrounding circumstances, including trade and export classifications, production descriptions, and affidavits, supported the view that the goods were treated in commerce as plastic goods. The Court held that no single universal test governs classification in such cases, and that for these goods the common parlance and trade usage tests were more appropriate than a bare comparison of the value of constituent materials. The subsequent introduction of a specific entry for suit cases from 1 July 1985 also showed that the earlier controversy arose only because no specific entry then existed.

Conclusion: The suit cases were plastic articles within Entry 113 and were not taxable as general goods under Section 5(1); the assessment order granting exemption was restored.

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