Broad construction of taxing entry on arms covered training grenades and strips; ordinary meaning controlled classification.

A taxing entry using the expression "all arms" was interpreted broadly to include hand grenades and bicat strips supplied for army training, because classification turns on the ordinary meaning and character of the goods rather than the purchaser's particular use. The inclusive reference to rifles, revolvers and pistols was treated as illustrative, not exhaustive, so the entry was not limited to those weapons alone. On that basis, the goods were held to fall within entry 12 of the First Schedule to the Tamil Nadu General Sales Tax Act for the applicable tax rate under section 8(2A) of the Central Sales Tax Act.

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Issues: Whether hand grenades and bicat strips supplied for army training fell within entry 12 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 as "all arms including rifles, revolvers, pistols and ammunition for the same", for the purpose of determining the applicable tax rate under section 8(2A) of the Central Sales Tax Act.

Analysis: The expression "all arms" was held to be wide enough to cover the goods in question when understood by their generally known description, without restricting classification to the particular use made by the purchaser. Their use only for training purposes did not alter their character as weapons capable of offence or defence. The inclusive words referring to rifles, revolvers and pistols were treated as illustrative and not exhaustive, so the entry was not confined to those articles alone.

Conclusion: The goods were held to fall within entry 12, and the Tribunal's view was upheld.

Ratio Decidendi: Where a taxing entry uses a general expression followed by illustrative examples, classification must be made by the ordinary meaning of the goods and not by their special use in a particular transaction.

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