Noscitur a sociis and commercial parlance confined "chemicals" to intermediates, excluding insecticidal end-products from the schedule entry.

In interpreting entry 4 of Schedule C to the Bombay Sales Tax Act, 1959, the Court applied noscitur a sociis to confine "chemicals" to goods of the same class as dyes, namely intermediary chemicals rather than finished products. It also applied the commercial parlance test and held that insecticidal products such as Aldrex, Dieldrex and Endrex would not ordinarily be understood in the market as "chemicals" within that entry. The rate structure and scheme of the schedules further indicated that entry 4 covered materials used in manufacturing further products, not end-products. The products were therefore held to fall under the residuary entry 22 of Schedule E.

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Issues: Whether the insecticidal products Aldrex, Dieldrex and Endrex are "chemicals" within entry 4 of Schedule C to the Bombay Sales Tax Act, 1959, or fall under the residuary entry 22 of Schedule E.

Analysis: The expression "chemicals" in entry 4 was read in the context of its association with "dyes". Applying the principle of noscitur a sociis, the Court held that the word "chemicals" in that entry denoted chemicals of the intermediary kind rather than end-products. The Court also applied the commercial parlance test and observed that goods of this kind would not ordinarily be understood in the market as mere "chemicals" for the purpose of the entry. The rate structure and scheme of the schedules also supported the view that entry 4 was intended for materials used in the manufacture of further products, not finished insecticidal end-products.

Conclusion: Aldrex, Dieldrex and Endrex do not fall within entry 4 of Schedule C and are covered by the residuary entry 22 of Schedule E; the answer to the reference is in the negative.

Ratio Decidendi: Where a taxing entry uses a general term alongside a narrower associated term, the general term may be confined by noscitur a sociis to goods of the same class, and the market or commercial meaning prevails over a technical or scientific description unless the statute provides otherwise.

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