JUDGMENT The judgment of the Court was delivered by C. V. JANI, J. - The question referred to this Court by the Gujarat Sales Tax Tribunal, Ahmedabad, under section 69 of the Gujarat Sales Tax Act, 1969, hereinafter referred to as "the Act" is the following : "Whether, on the facts and in the circumstances of this case, the Tribunal was right in law in holding that the opponent's disputed sale of 'white printed wrappers' was not sale covered by the residuary entry 13 of Schedule III to the Gujarat Sales Tax Act, 1969, but was covered by the expression 'paper, including newsprint and straw boards and card boards but excluding paper specified in entry 12 and entry 31A in this Schedule', as used in entry 31 of Schedule II, Part A to the Gujarat Sales Tax Act, 1969 ?" 2. The factual background in which this reference has arisen is the following : The opponent M/s. Dipak Lalbhai & Co. manufacturing printed wrappers sold white printed wrappers to Calico Mills as per invoice dated May 12, 1982, and requested the Deputy Commissioner of Sales Tax under section 62 of the Act, to determine the rate of tax payable on such sale. It was urged that the printed wrapper which was sold for packing of cotton cloth was nothing but a kind of paper falling under entry 31 of Schedule II, Part A to the Act, and that they were not excluded as per entry 12. 3. A reference was made to a judgment of the Supreme Court in State of Uttar Pradesh v. Kores (India) Ltd. [1977] 39 STC 78, wherein the question whether carbon paper was a paper was involved. The attention of the Deputy Commissioner was also drawn to the amendment introduced in entry 12 of Schedule II, Part A to the Act with effect from April 1, 1983, whereby "printed wrappers of paper" were sought to be added as sub-entry (xvii). The Deputy Commissioner held that as there was no specific entry for white printed wrappers in any of the Schedule on the relevant date, such wrappers would be covered by the residuary entry 13 of Schedule III to the Act. 3.1 The opponent-firm challenged this determination order by filing appeal No. 1/84. The Deputy Commissioner held that as there was no specific entry for white printed wrappers in any of the Schedule on the relevant date, such wrappers would be covered by the residuary entry 13 of Schedule III to the Act. 3.1 The opponent-firm challenged this determination order by filing appeal No. 1/84. The Gujarat Sales Tax Tribunal after referring to the relevant entries and judgments allowed the appeal and held that the Legislature had not intended such wrappers of papers to be covered by the said residuary entry 13. 4. At the instance of the Revenue, the aforesaid question is referred to this Court for determination. 5. The relevant entries in Schedule II, Part A of the Act are the following : "31. Paper, including newsprint and straw boards and card boards but excluding paper specified in entries 12 and 31A in this Schedule. 12. The following articles, that is to say - (i) and (ii) .........; (iii) brown paper, craft paper, butter paper and cellophane paper; (iiia) .............. (iv) to (viii) .......; (ix) Paper labels and such other packing materials as the State Government may, by a notification in the Official Gazette, specify for the purpose of this entry. 31A. Art paper, suncoat, art card, art board, ivory card, chrome coated paper, cheque paper, imitation art paper, bible paper and silver cote art paper." 6. The residuary entry No. 13 in Schedule III reads as under : "13. All goods other than those specified from time to time in sections 18 and 19A and in Schedules I and II and in the preceding entries." 7. Mr. D. C. Dave, learned counsel appearing on behalf of M/s. H. V. Chhatrapati for the applicant-State, submitted that the goods sold by the opponent-firm did not fall in any of the entries in Schedule I and Schedule II and, therefore, they would be covered by the residuary entry 13 of Schedule III. He submitted that such wrappers would not retain their quality as paper as they became printed papers for a specific purpose of wrapping cotton textile goods and they could not be used for any other purpose. In essence Mr. Dave's submission was that it lost its identity as paper, but became altogether a different commercial commodity. According to Mr. He submitted that such wrappers would not retain their quality as paper as they became printed papers for a specific purpose of wrapping cotton textile goods and they could not be used for any other purpose. In essence Mr. Dave's submission was that it lost its identity as paper, but became altogether a different commercial commodity. According to Mr. Dave the specific entry 31 which ascribed certain meaning to "paper" included newsprint, straw boards and card boards and not printed wrappers and moreover it excluded papers specified in entry 12 and entry 31A. It is nobody's say that entry 31A would come into play in this case. Hence Mr. Dave's whole thrust was on entry 12 in Part A of Schedule II. According to Mr. Dave as white printed wrappers manufactured and sold by the opponent-firm did not fall in any of the specific entries at entry 12 nor they were included in newsprint and straw board or card board included in entry 31, they would fail under the residuary entry 13 of Schedule III. He further submitted that the amendment introduced in entry 12 subsequently with effect from April 1, 1983, by addition of "printed wrappers of paper" would fortify the view he was propounding inasmuch as it reflected the intention of the Legislature. 8. In our view, these submissions do not have any merit. Prima facie the term "paper" appearing in entry 31 of Schedule II, Part A does not define the term. Hence it has to be understood in its common parlance meaning. Under entry 31 the term "paper" would also include newsprint, straw board and card board. It cannot therefore be said that the term would not include printed wrappers. If there are various species of paper because of different modes of manufacture and use, the meaning of genus is not narrowed down except by specific exclusion, and the only items which are excluded are in entry 12 and entry 31A. Even according to Mr. Dave the wrappers do not fall under entry 12, and, therefore, specific entry 31 relating to "paper" of all kinds except excluded category would govern the field. Even according to Mr. Dave the wrappers do not fall under entry 12, and, therefore, specific entry 31 relating to "paper" of all kinds except excluded category would govern the field. The amendment of the entry by addition of sub-entry (xii) "printed wrappers of paper" merely shows the intention of the Legislature to lower down the rate of tax of such wrappers, as under entry 31 wrappers would be taxable at the rate of six paise in the rupee, while under entry 12 the article would be taxable at the rate of four paise in the rupee. 9. The Tribunal has referred to the judgment of the Supreme Court in State of Uttar Pradesh v. Kores (India) Ltd. [1977] 39 STC 8. The Supreme Court was concerned with the question whether carbon paper was or was not paper as envisaged by a certain entry by notification issued under section 3-A of the U.P. Sales Tax Act, 1948. The term "paper" was not defined under the said Act or rules made thereunder, and, therefore, it was assigned the meaning as understood by the persons dealing in and using the article. It was held that the carbon paper could not be used for the purposes of bearing writing, printing, packing, drawing, decorating or covering the walls to which the commodity usually known as paper would be put. After referring to the meaning of the term "paper" appearing in The Shorter Oxford English Dictionary, Encyclopedia Britannica and The Randon House Dictionary of the English Language, the Supreme Court observed : "From the above definitions, it is clear that in popular parlance, the word 'paper' is understood as meaning a substance which is used for bearing writing, or printing, or for packing, or for drawing on, or for decorating, or covering the walls. Now carbon paper which is manufactured by coating the tissue paper with a thermosetting ink (made to a liquid consistency) based mainly on wax, nondrying oils, pigments and dyes by means of a suitable coating roller and equalising rod and then passing it through chilled rolls cannot be used for the aforesaid purposes but is used according to 'The Randon House Dictionary of the English Language' between two sheets of plain paper in order to reproduce on the lower sheet that which is written or typed on the upper sheet, i.e., making replicas or carbon copies, cannot properly be described as paper." The emphasis was "on the common parlance test" and it was found that the paper could be used for packing also, which is the function a printed wrapper is supposed to discharge. This judgment is referred to and relied upon by the Supreme Court in the context of excise laws, in Collector of Central Excise v. Krishna Carbon Paper Co. [1989] 72 STC 280; (1988) 37 ELT 480 . In Swastik Products v. Superintendent of Central Excise (1980) ELT 164 a Division Bench of this Court was concerned with the question whether the petitioner in that case was liable to pay duty on paper purchased by it from manufacturers and then printed by it on one side. This Court answered the question in the negative by holding that colouring the paper which is already manufactured is not a process in the manufacture of paper nor can it be said to be one incidental or ancillary to the manufacture of paper. Since the goods in question had already suffered excise duty which was paid by the manufacturer, the petitioner was not held liable to pay excise duty on flint paper coloured by it. This would squarely meet the submission made on behalf of the Revenue that printing of paper for supply of printed paper to the textile mill would involve manufacture and would bring into existence a different taxable commodity. This would squarely meet the submission made on behalf of the Revenue that printing of paper for supply of printed paper to the textile mill would involve manufacture and would bring into existence a different taxable commodity. A similar view had also been taken earlier by another Division Bench of this Court in Navgujarat Paper Industries v. Superintendent of Central Excise (1977) ELT (J. 67) and the court had observed in para 17 that : "Similarly mere printing of designs and monograms and other description of goods regarding to quality (sic) of the name of manufacturer does not convert packing or wrapping paper into another kind of paper. It still continues to be printing or wrapping paper on which something has been printed." Hence the question involved in this reference is directly covered by the earlier judgment of this Court. 10. In this view of the matter the question requires to be answered in the affirmative and it is answered accordingly. There will be no order as to costs in the circumstances of the case. Reference answered in the affirmative.