Common commercial meaning of "dyes" covers colour-powders sold for dyeing, not the residuary entry.

Colour-powders sold for dyeing cloth and other articles fall within the common and commercial meaning of "dyes" in Entry 25 of Schedule II, Part II of the M.P. General Sales Tax Act, 1958. The term was not to be confined by scientific or technical usage, and ejusdem generis did not justify excluding a distinct commercial commodity merely because it appeared alongside paints, varnishes and enamels. The later inclusion of "dyes" in the entry also supported its treatment as a separate taxable category, so the goods were taxable under Entry 25 rather than the residuary entry.

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Issues: Whether colour-powders fall within the expression "dyes" in Entry 25 of Schedule II, Part II of the M.P. General Sales Tax Act, 1958, and are therefore taxable under that entry rather than under the residuary entry.

Analysis: The expression "dyes" in a sales tax schedule must be construed according to its common and commercial meaning, not by scientific or technical meaning. Colour-powders sold in the market for dyeing cloth and other articles are ordinarily understood as dyes, even if they must be diluted or mixed before use. The context of Entry 25 did not justify confining the word "dyes" by applying ejusdem generis to exclude a distinct commodity merely because it appears alongside paints, varnishes, enamels and similar items. The reasoning also treated the later addition of "dyes" to the entry as indicating that the item was intended to stand as a separate commercial category.

Conclusion: Colour-powders fall within the term "dyes" in Entry 25 of Schedule II, Part II, of the M.P. General Sales Tax Act, 1958, and are liable to tax under that entry.

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