Statutory interpretation of tariff entries limits "machinery" to electrically operated goods under the sales-tax schedule.

An amended sales-tax entry must be read in its statutory context, and a general word inserted into a composite tariff item does not expand coverage beyond the class indicated by the associated words. Applying ordinary construction and ejusdem generis, the Madras HC held that the word "machinery" in entry 41 remained confined to electrically operated machinery because the entry's language and structure showed that the qualifying words continued to control its scope. Textile machinery that was not electrical goods therefore did not fall within the entry and was not subject to single-point levy under it; the assessments were set aside and normal multi-point assessment applied.

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Issues: Whether textile machinery sold by the petitioners fell within entry 41 of the First Schedule to the Madras General Sales Tax Act, 1959, as amended, so as to attract single-point levy at the higher rate.

Analysis: The amended entry inserted the word "machinery" between "electrical goods" and "instruments" and placed the qualifying words "the use of which cannot be had except with the application of electrical energy" at the end. Applying ordinary rules of construction and the principle of ejusdem generis, the word "machinery" had to take colour from the associated words in the entry and could not be read as an independent general category covering all machinery irrespective of its electrical character. The amendment did not alter the basic complexion of the entry so as to include non-electrical machinery. The administrative clarifications relied upon also indicated that the expression was intended to mean electrical machinery only.

Conclusion: Textile machinery which was admittedly not electrical goods did not fall within entry 41 and could not be subjected to single-point levy under that entry.

Final Conclusion: The impugned single-point assessments were set aside and the petitioners remained liable only to normal multi-point assessment.

Ratio Decidendi: An amended tariff or sales-tax entry must be construed in its statutory context, and a general word inserted in a composite entry will not expand the entry beyond the class indicated by the associated words where the scheme and language show that the category remains confined to electrically operated goods.

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