Composite tariff entries are read by commercial genus; iron weights and measures were held outside "mill-stores and hardware".

A composite sales tax entry must be read as a whole in its commercial sense, and an item falls within it only if it shares the common commercial genus of the associated goods. On that approach, iron weights and measures were held not to fall within "mill-stores and hardware", because hardware could not be read as extending to every article made of iron or metal; the goods were treated as metal wares, with tax applying at the rate under the later notification for the subsequent period.

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Issues: Whether iron weights and measures were covered by the expression "mill-stores and hardware" in the relevant sales tax notification, and consequently whether their turnover was taxable at the higher rate claimed by the Revenue for the relevant periods.

Analysis: The expression "mill-stores and hardware" was construed as a composite entry covering goods belonging to a related class and sharing a common commercial character. The word "hardware" was not treated as an isolated expression capable of extending to every article made of iron or metal. Applying the established commercial understanding of the entry and the limits indicated by earlier decisions, weights and measures were found to have no common factor with mill-stores or hardware as used in the notification. They were instead treated as metal wares liable to tax at the rate applicable under the subsequent notification for the later period.

Conclusion: Iron weights and measures were not covered by the expression "mill-stores and hardware". The Revenue's contention failed, and the turnover was taxable at 2 paise per rupee up to 31st May, 1963, and at 3 paise per rupee thereafter under the later notification.

Ratio Decidendi: A composite tariff or exemption entry must be read as a whole in its commercial sense, and an item falls within it only if it belongs to the same commercial genus and shares the common character of the associated goods.

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