Contextual interpretation of taxing entries kept canvas cloth within the cloth item, not the goods made from canvas entry.

A taxing notification must be construed in its grammatical and contextual setting. Item 9, read with the schedule and note, was directed to manufactured goods made out of specified materials, so it covered canvas goods but not canvas cloth as such. The absence of commas did not widen the entry, and the reference to goods "manufactured" reinforced that the provision applied to finished articles rather than the raw material or textile cloth. Canvas cloth was instead treated as cloth manufactured by mills and fell within item 2 of the schedule.

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Issues: Whether canvas cloth was covered by item No. 9 of the sales tax notification as goods made out of canvas, or whether it fell under item No. 2 as cloth manufactured by mills.

Analysis: The notification issued under section 3-A of the U.P. Sales Tax Act treated specified goods as taxable at a special point and rate. Reading item No. 9 in context, the word "goods" was held to qualify each of the preceding words, including "canvas", so that the entry covered canvas goods and not canvas cloth as such. The absence of commas did not alter that construction. The Court further noted that the third column's reference to goods "manufactured" supported the view that the entry was directed to manufactured goods and not to canvas as a raw material or textile cloth. The note attached to the schedule, referring to leather goods, also reinforced that item No. 9 was concerned with goods made out of the listed materials. By contrast, canvas cloth was treated as cloth manufactured by mills and therefore fell within item No. 2 of the schedule.

Conclusion: Canvas cloth as distinct from goods made out of canvas was not covered by item No. 9, but was covered by item No. 2 of the notification dated 8th June, 1948 as amended. The reference was answered in favour of the Revenue.

Ratio Decidendi: In construing a taxing notification, the words of an entry must be read in their grammatical and contextual setting, and where the schedule shows that the entry is aimed at manufactured goods made out of specified materials, the entry will not extend to the raw material or to a different class of goods expressly covered elsewhere in the schedule.

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