Common parlance test governs tariff classification of toughened glass as glassware under a broad tax entry.

Toughened glass manufactured and sold by the assessee was treated as falling within Tariff Item No. 39 of the U.P. Sales Tax Act as glass and glassware, rather than as an unclassified item attracting a lower rate. The classification depended on the wording of the tariff entry, which covered goods and wares made of glass, and on the common parlance test applicable to taxing statutes. The SC held that tariff entries must be understood in their popular sense, not by scientific or technical meaning, and that the entry's broad language was sufficient to include toughened glass. The challenge to the High Court's view failed.

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Issues: Whether toughened glass manufactured and sold by the assessee fell within Tariff Item No. 39 of the U.P. Sales Tax Act, 1998 as glass and glassware or was an unclassified item liable to lower tax.

Analysis: The classification turned on the language of Tariff Item No. 39, which covers all goods and wares made of glass, and on the principle that tariff entries in taxing statutes are to be understood in their popular sense rather than by scientific or technical meanings. The Court relied on the broader sweep of the entry and the settled common parlance test, noting that the description of the goods and the scope of the entry were sufficient to include the manufactured toughened glass.

Conclusion: The toughened glass manufactured by the assessee was held to fall within Tariff Item No. 39, and the challenge to the High Court's view failed.

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