Noscitur a sociis limited "perfumery" to personal-use goods, excluding dhoop and agarbatti from the tax entry.

The grouped words in Entry No. 16, "cosmetics, perfumery and toilet goods," had to be read together. Applying noscitur a sociis, "perfumery" was confined to articles used upon the person and took colour from the associated words "cosmetics" and "toilet goods." On that contextual reading, "dhoop" and "agarbatti," being primarily used for religious ceremonies rather than personal hygiene or pleasure, did not fall within the entry, and the assessment treating them as perfumery could not stand. The earlier decision on "dhoop" and "dhoop-batti" was distinguishable because the relevant expression there stood alone and was not controlled by surrounding words.

---

---

Issues: Whether "dhoop" and "agarbatti" fell within the expression "perfumery" in Entry No. 16 of Schedule A to the Punjab General Sales Tax Act, 1948, as applicable to the relevant assessment period.

Analysis: The grouped expressions in the entry, namely "cosmetics, perfumery and toilet goods", had to be read together. Applying noscitur a sociis, the word "perfumery" drew colour from the associated words "cosmetics" and "toilet goods" and was therefore confined to articles used upon the person, like cosmetics and toilet goods. On that contextual reading, "dhoop" and "agarbatti", which are primarily used for religious ceremonies and not for personal hygiene or pleasure, did not fall within the entry. The earlier decision treating "dhoop" and "dhoop-batti" as perfume was distinguishable because the relevant expression there stood by itself and was not controlled by surrounding words.

Conclusion: "Dhoop" and "agarbatti" were not covered by the expression "perfumery" in Entry No. 16, and the assessment treating them as such could not stand.

Ratio Decidendi: Where words in a tax entry are grouped together, each takes colour from the others, and a general expression must be confined to the class indicated by the associated words.

---