Noscitur a sociis narrows "old machinery" in a taxing entry to non-functional equipment, excluding a working power plant.

The expression "old machinery" in the U.P. Sales Tax Act notification was construed narrowly because it appeared alongside the associated words "discarded, unserviceable or obsolete." Applying noscitur a sociis, the general word "old" was confined to machinery that had become non-functional or non-usable, rather than merely aged. A thermal power plant sold in perfect working condition therefore did not fall within entry No. 15 and was not subject to sales tax under that entry.

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Issues: Whether the expression "old machinery" in entry No. 15 of the notification issued under section 3-A of the U.P. Sales Tax Act, 1948, covered a thermal power plant sold in perfect working condition so as to attract sales tax.

Analysis: The entry grouped the words "old, discarded, unserviceable or obsolete" together in relation to machinery. The expression "old" was held to be vague and general when read by itself, and there was no indication that it was intended to bear an unrestricted meaning. Applying noscitur a sociis, the associated words were treated as cognate and the wider expression "old" was confined to a sense analogous to "discarded, unserviceable or obsolete". On that construction, machinery would fall within the entry only if it had become non-functional or non-usable. The power plant sold by the appellant was still in perfect running condition and had not become non-functional or unserviceable.

Conclusion: The sale of the thermal power plant did not fall within entry No. 15 and was not exigible to tax.

Ratio Decidendi: Where a general word in a tariff or taxing entry is grouped with more specific associated words and the context does not show a contrary legislative intent, the general word must be construed in a restricted sense taking colour from the associated words.

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