Jewellery classification for sales tax includes gold ornaments with imitation stones; their negligible value does not change taxability.

Gold ornaments made of pure gold and set with imitation stones were treated as "jewellery" for sales tax purposes under the Orissa notifications. Because the term was undefined, its ordinary meaning was applied, and that meaning was held to include ornaments with imitation stones as well as those with precious stones. The later notification expressly referring to jewellery and imitations confirmed that imitation stones did not take the article outside the category. The negligible value of the imitation stones was immaterial, and the ornaments remained taxable as jewellery.

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Issues: Whether gold ornaments manufactured by the dealer, though set with imitation stones of negligible value, were liable to sales tax as "jewellery" under the relevant Orissa notifications.

Analysis: The expression "jewellery" was not defined in the notifications, so its ordinary meaning had to be gathered from the dictionary. That meaning showed that while jewellery ordinarily connotes ornaments with precious stones, the term is not confined to such ornaments and may also extend to ornaments with imitation stones. The later notification of 3 July 1951, which expressly referred to jewellery and imitations, confirmed that imitation stones did not exclude an ornament from the category of jewellery. The value of the imitation stones was immaterial.

Conclusion: Gold ornaments made of pure gold and set with imitation stones fell within the expression "jewellery" and were taxable.

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