JUDGMENT V. K. SINGHAL, J. - Reassessment order for the year 1988-89 dated December 21, 1991 passed under section 12(3) of the Karnataka Sales Tax Act, 1957 has been assailed in these writ petitions. The assessment under the Central sales tax has also been challenged in these petitions. The dispute relates to sale of filter cloth. The assessing authority has levied the tax on the ground that the commodity is man-made fabric and is not textile in common parlance. Reliance was placed on the circular issued by the Commissioner of Commercial Taxes dated August 25, 1989. 2. Relevant entry 8A of the Fifth Schedule under which exemption is claimed and assessments were finalised earlier is as under : "Entry 8A of Schedule V : All varieties of textile namely, cotton, woollen or artificial silk including rayon or nylon whether manufactured in mills, powerlooms or handlooms and hosiery cloth in lengths." 3. The word "textile" was interpreted by the apex Court in Delhi Cloth & General Mills Co. Ltd. v. State of Rajasthan [1980] 46 STC 256. The dispute was with regard to rayon tyre cord fabric. It was observed that it may be that unlike the cotton, silk, woollen and rayon fabrics used as wearing apparel or furnishing material, the rayon tyre cord fabric is not directly employed for the satisfaction of a domestic need. Nonetheless, as an integral and vital constituent of an automobile tyre it is intimately involved in the diurnal activity of human life. Definition of "fabric" in various dictionaries also taken note of and it was held that tyre cord fabric is a fabric. In Porritts & Spencer (Asia) Ltd. v. State of Haryana [1978] 42 STC 433 (SC) it was observed at page 437 thus : "Moreover a textile need not be of any particular size or strength or weight. It may be in small pieces or in big rolls : it may be weak or strong, light or heavy, bleached or dyed, according to the requirement of the purchaser. The use to which it may be put is also immaterial and does not bear in its character as a textile. It may be used for making wearing apparel, or it may be used as a covering or bedsheet or it may be used as tapestry or upholstery or as duster for cleaning or as towel for drying the body. The use to which it may be put is also immaterial and does not bear in its character as a textile. It may be used for making wearing apparel, or it may be used as a covering or bedsheet or it may be used as tapestry or upholstery or as duster for cleaning or as towel for drying the body. A textile may have diverse uses and it is not the use which determines its character as textile. It is, therefore, no argument against the assessee that 'dryer felts' are used only as absorbents of moisture in the process of manufacture in a paper manufacturing unit. That cannot militate against 'dryer felts' falling within the category of 'textiles', if otherwise they satisfy the description of 'textiles'." 4. The word "textile" is not defined under the Karnataka Sales Tax Act. Keeping in view the definitions given in dictionaries and the judgments of the apex Court, any fabric which is having warp and weft is a textile. Non-woven fabrics are also textile fabrics made of carded web or fibre web held together by adhesives. Entry 8A of the Fifth Schedule refers to all varieties of textiles. Those varieties may be of cotton, woollen or artificial silk. Non-wovens fabrics have been defined in Manual of Non-wovens by Prof. Dipling and Dr. Radko Krama as under : "Non-woven fabrics - Textile fabrics made of a fibrous layer which may be a carded web, a fibre web, a system of random laid or oriented fibres or threads, possibly combined with textile or non-textile materials such as conventional textile fabrics, plastic films, foam layers, metal foils, etc., and forming with them a mechanically bound or chemically bonded textile product." With the rapid development of science and technology in textile, there is partial/complete elimination of conventional textile operations such as weaving, knitting, spinning, roving or carding. 5. In Porritts & Spencer (Asia) Ltd. v. State of Haryana [1978] 42 STC 433 (SC) referred to above, it was observed that in a taxing statute words of every day use must be construed not in their scientific or technical sense but should be understood in common parlance. Even knitted fabric could be a textile. 6. 5. In Porritts & Spencer (Asia) Ltd. v. State of Haryana [1978] 42 STC 433 (SC) referred to above, it was observed that in a taxing statute words of every day use must be construed not in their scientific or technical sense but should be understood in common parlance. Even knitted fabric could be a textile. 6. The word "namely" used in entry 8A of the Fifth Schedule restricts the scope of textile and would not include other textiles Re, made of jute, etc., and only textiles of cotton, woollen or artificial silk would be covered by the entry. The word artificial silk includes rayon, nylon by the extended definition. These fabrics whether manufactured in mill, handloom or powerloom or hosiery cloth in length also falls in the category of textile. The assessing authority has considered filter cloth as non-woven. Filter cloth has been considered to be non-woven on the basis of Excise Gate Pass-I (GP. I) which has been subjected to duty under item 5603. Chapter 56 of the Central Excise Tariff Act, 1985 refers to wadding, felt and non-wovens, etc. The assessing authority has not gone to the exact nature of the commodity. Learned counsel for the petitioner contended that it was because there was no warp and weft and it was not a woven fabric it was not considered as a textile. The interpretations of textile given in Porritts & Spencer (4sia) Ltd. [1978] 42 STC 433 (SC) and Delhi Cloth Mills Co. Ltd. [1980] 46 STC 256 (SC) cases are relevant. Even if filtered cloth is not having warp and weft and satisfies the criteria laid down in the judgment referred to above, no tax could be levied. Reassessment order could not have been passed on the basis of the circular issued by the department which are accordingly quashed. If it is found that even in commercial parlance filter cloth could be considered to be textile fabric, then no tax could be levied. If filter cloth is knitted, as alleged then it could be considered to be woven for the purpose of exemption under entry 8A of the Fifth Schedule. If it is found that even in commercial parlance filter cloth could be considered to be textile fabric, then no tax could be levied. If filter cloth is knitted, as alleged then it could be considered to be woven for the purpose of exemption under entry 8A of the Fifth Schedule. Since no material has been placed before this Court as to what is the process of manufacture and also how die filter cloth is made, which also is otherwise in the exclusive jurisdiction of the assessing authority, the assessing authority would be free to proceed for reassessment if filter cloth is not considered to be a textile. Writ petitions are allowed with the above observation. Writ petitions allowed.