Ejusdem generis limits "toilet requisites"; a safety razor falls outside the higher sales tax entry.

A safety razor was held not to fall within the expression "cosmetics and toilet requisites" in item 6 of Notification No. 905/X issued under section 3-A of the U.P. Sales Tax Act. The entry was read in context, and the general words "toilet requisites" were confined by ejusdem generis to articles of the same class as cosmetics, covering toilet preparations and similar items but not tools, instruments, or devices such as razors. The argument that the article must be usable without outside aid was not treated as the decisive test. Any ambiguity in the fiscal entry was resolved in favour of the assessee, so the razor remained taxable under section 3 rather than at the higher rate under section 3-A.

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Issues: Whether a safety razor manufactured by the assessee could be classified as a cosmetic or a toilet requisite under item 6 of Notification No. 905/X, and thereby taxed at the higher single-point rate.

Analysis: The notification was issued under section 3-A of the U.P. Sales Tax Act and separately listed a number of specific goods, showing that the expression "cosmetics and toilet requisites" was not intended to be read in an unlimited dictionary sense. Although the word "toilet" is capable of a wide meaning, the context required the general words "toilet requisites" to be confined by the principle of ejusdem generis to articles of the same genus as cosmetics. On that construction, the entry covered toilet preparations and similar articles, but not tools, instruments, or devices such as razors. The alternative argument that the article must be usable without any outside aid was also not accepted as the decisive test, but the razor still failed to fall within the notified class. The ambiguity in the entry, if any, was also resolved in favour of the assessee.

Conclusion: A safety razor is neither a cosmetic nor a toilet requisite within item 6 of Notification No. 905/X. It is taxable under section 3 of the U.P. Sales Tax Act and not at the higher rate under section 3-A.

Ratio Decidendi: Where a taxing entry uses specific words followed by general words, the general words may be restricted by ejusdem generis to the same class as the specific words, and an ambiguous fiscal entry is construed in favour of the assessee.

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