Broad construction of "ornaments" covered stone-studded jewellery under the earlier tax notification at the higher rate.

The term "ornaments" in the 5 April 1961 notification was construed broadly to include jewellery studded with pearls or precious stones, including items made of gold and silver. The later 31 July 1967 notification, which separately dealt with jewellery containing precious or semi-precious stones at a higher rate, did not narrow the earlier notification's scope. Accordingly, such jewellery fell within "ornaments" and was taxable at 3 per cent, not as an unspecified item at 2 per cent.

---

---

Issues: Whether jewellery studded with precious stones and made of gold and silver fell within the expression "ornaments" in the notification dated 5th April, 1961, so as to be taxable at 3 per cent., or whether it was an unspecified item taxable at 2 per cent.

Analysis: The expression "ornaments" in the notification was construed as comprehensive in scope. It was held to include ornaments of all kinds, including jewellery studded with pearls or precious stones. The later notification of 31st July, 1967, which separately referred to jewellery containing precious or semi-precious stones and imposed a higher rate, did not justify excluding such jewellery from the earlier notification. The later notification was treated as an instance of subjecting costlier ornaments to a higher rate without altering the earlier breadth of the term "ornaments".

Conclusion: Jewellery in which precious stones were studded with gold and silver was covered by the term "ornaments" in the notification dated 5th April, 1961, and was taxable at 3 per cent., not as an unspecified item at 2 per cent.

---