Trade parlance test governs sales tax classification; sports goods containing leather are not automatically leather goods.

Sports goods such as footballs, cricket balls and hockey balls were held, on ordinary trade and popular understanding, not to be "leather goods" merely because leather was an ingredient. The decisive test for sales tax classification is how the goods are understood in common or market parlance, not their technical composition alone. Industry classification materials supported a clear distinction between leather goods and sports goods, and the absence of a separate entry for sports goods did not justify expanding the leather goods entry. On that basis, the revenue's classification was rejected and the disputed turnover could not be taxed as leather goods.

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Issues: Whether sports goods such as footballs, cricket balls and hockey balls, though containing leather as an ingredient, fall within the expression "leather goods" under Item 116 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959.

Analysis: In classifying goods for sales tax purposes, the decisive test is the sense in which the goods are understood in common or trade parlance, and not their technical composition alone. Leather may be an important ingredient in certain sports goods, but that does not make the articles themselves leather goods if, in the market and in ordinary usage, they are understood as sports goods. The relevant materials, including standard industry classifications, showed a clear distinction between leather goods and sports goods. The absence of a separate entry for sports goods did not justify treating every sports item containing leather as leather goods. Since the items in question were not commonly regarded as leather goods, the revenue's broader construction could not be accepted.

Conclusion: The items in dispute are not leather goods within Item 116, and the classification adopted by the revenue is unsustainable; the issue is decided in favour of the assessee.

Final Conclusion: The turnover relating to the disputed sports goods was not liable to be taxed as leather goods, and the appeal succeeded.

Ratio Decidendi: For sales tax classification, an article must be treated according to its ordinary trade and popular understanding, and not merely because it contains a particular ingredient.

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