Broad construction of "sanitary fittings" under a sales tax notification covers sanitary goods and fixtures, not just accessories.

The expression "sanitary fittings" in Notification No. ST-905/X dated 31 March 1956 was construed broadly by reading the notification as a whole, with its grouped entries and express exclusions showing that the term was not limited to minor accessories or parts. On that basis, wash-basins, commodes, urinals, cisterns, pipes and similar sanitary goods were treated as falling within the category of sanitary fittings. A distinction drawn in another government publication between "sanitary wares" and "sanitary fittings" was held to be context-specific and not controlling for the U.P. Sales Tax Act notification.

---

---

Issues: Whether wash-basins, commodes, urinals, cisterns, pipes and similar sanitary goods fell within the expression "sanitary fittings" in Notification No. ST-905/X dated 31st March, 1956, so as to attract the enhanced rate of sales tax.

Analysis: The expression "sanitary fittings" had to be construed with reference to the scheme of the notification itself. The listed entries in the notification showed that commodities were grouped by broad categories, and where exclusions were intended the notification expressly stated them. On that structure, the expression was not confined to minor accessories or parts, but covered the entire category of sanitary goods and fixtures. The distinction drawn in another government publication between "sanitary wares" and "sanitary fittings" was held to be context-specific and not controlling for the notification under the U.P. Sales Tax Act.

Conclusion: Wash-basins, commodes, urinals, cisterns, pipes and similar items were held to fall within "sanitary fittings" in Notification No. ST-905/X dated 31st March, 1956, and were liable to the enhanced rate of taxation.

---