Ordinary meaning of "perfume" includes incense-like articles emitting agreeable odour when burned, bringing dhoop and dhoop-batti within tax entry.

A notified tax entry using the expression "perfume" was construed in its ordinary and dictionary sense, not as a term limited to substances giving off fragrance only in their natural state. The Court treated the expression as broad enough to include articles that emit an agreeable odour when burned or otherwise processed, unless the notification clearly restricts the meaning. On that construction, dhoop and dhoop-batti were covered by the notified entry and attracted single-point sales tax accordingly.

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Issues: Whether dhoop and dhoop-batti fall within the expression "perfume" in item 37 of the notification issued under section 3-A of the U.P. Sales Tax Act and are therefore liable to single-point sales tax.

Analysis: The notification used the expression "scents and perfumes" and the question turned on the ordinary meaning of "perfume". The Court held that the word was not confined to substances emitting fragrance in their natural state, but extended to substances which, when burned or otherwise subjected to a process, emit an agreeable odour. The ordinary and dictionary meanings of the term supported an inclusive construction covering incense-like articles. On that construction, dhoop and dhoop-batti were within the notified entry.

Conclusion: Dhoop and dhoop-batti fall within the category of "perfume" under item 37 of the notification and are liable to tax accordingly, against the assessee and in favour of the Revenue.

Ratio Decidendi: A notified expression such as "perfume" must be construed in its ordinary sense, and includes substances capable of emitting an agreeable odour when burned or otherwise processed, unless the notification clearly restricts it.

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