Trade and commercial parlance controls plywood classification, so shuttering plywood was not treated as structural plywood for exemption.

Shuttering plywood was held not to be structural plywood for exemption purposes because classification depended on its identity in trade and commercial parlance, supported by separate Indian Standards for the two products. The revenue's advertisement described it as concrete shuttering plywood and did not establish it as structural plywood. Dictionary meanings were treated as unsafe for classification where market understanding and standard specifications pointed to distinct commercial identities. The product therefore continued to qualify as commercial plywood for the notification benefit.

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Issues: Whether shuttering plywood is to be treated as structural plywood, so as to deny the benefit of Notification No. 55/79-C.E. dated 1.3.79.

Analysis: The relevant test was the meaning of the goods in trade and commercial parlance. The advertisement relied upon by the Revenue described the product as concrete shuttering plywood and did not identify it as structural plywood. Separate Indian Standards existed for structural plywood and shuttering plywood, indicating that they were understood as distinct products in the market. In these circumstances, dictionary definitions were not a safe guide for classification where trade understanding and standards evidence pointed otherwise.

Conclusion: Shuttering plywood is not structural plywood and continues to qualify as commercial plywood for the notification benefit.

Ratio Decidendi: For classification under an exemption notification, the decisive criterion is the product's identity in trade and commercial parlance, supported where available by standard specifications, and not a mere dictionary meaning.

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