Common parlance controls goods classification: industrial woollen felt treated as machinery part, not fabric, under VAT schedule.

For classification under the Madhya Pradesh VAT Act, the common parlance understanding and actual use of the product control over its label. Woollen felt supplied for industrial use and employed mainly as a conveyor belt or machinery component in the paper industry was not treated as fabric under the specific schedule entry, because that entry covered textile-like goods ordinarily used as towels, chadars, quilts, bed covers and similar articles. The earlier textile precedent was distinguished as involving a broader statutory entry. The authorities' view was upheld, and the product was classified under the residuary entry as a machinery part.

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Issues: Whether the woollen felt component manufactured for industrial use is classifiable as a fabric under the relevant schedule entry or as a machinery part under the residuary entry of the Madhya Pradesh Value Added Tax Act, 2002.

Analysis: The decisive consideration was the commercial and popular understanding of the product and its actual use. The material showed that the product, though described as felt, was supplied for industrial purposes and used mainly as a conveyor belt or machinery component in the paper industry. The Court found that the fabric entries in the VAT schedule were aimed at goods ordinarily used as textiles or dress materials such as towels, chadars, quilts, bed covers and similar articles, and the assessee had not shown that the product was used in that sense. The reliance on the earlier textile classification precedent was rejected because the statutory entry there was materially different and broadly covered all varieties of textiles, whereas the present schedule contained a narrower product-based entry. The Court therefore accepted the classification adopted by the taxing authorities and the appellate board.

Conclusion: The woollen felt component was not classifiable as fabric under the claimed schedule entry and was liable to be treated as a machinery part under the residuary entry.

Final Conclusion: No question of law arose for interference, and the tax authorities' classification was sustained.

Ratio Decidendi: For goods classification under a taxing statute, the common parlance and actual use of the product prevail over nomenclature, and a residuary entry applies where the product does not fit within the specific fabric entry on a proper commercial understanding.

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