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Issues: Whether ingoor and sindoor were taxable under section 3-A of the U.P. Sales Tax Act as cosmetics and toilet requisites or under section 3 of the U.P. Sales Tax Act as unclassified items.
Analysis: The articles were found to be used only by married women to signify married status and not for beautifying the face or body. On that factual basis, they did not answer the meaning of cosmetics or toilet requisites. Applying the principle of ejusdem generis, the expression "toilet requisites" had to be confined to articles of the same genus as cosmetics, and could not be extended to these articles. The alternative characterisation as dyes and colours was not challenged.
Conclusion: Ingoor and sindoor were not taxable under section 3-A of the U.P. Sales Tax Act. They were taxable under section 3 of the U.P. Sales Tax Act as unclassified items, in favour of Revenue.