Cycle rickshaws excluded from "cycle combinations" under the sales tax schedule, based on statutory context and vehicle character.

Cycle rickshaws were construed as outside entry 38 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959. The expression "cycle combinations" was read in its statutory context, with the associated words and schedule arrangement indicating linkage to "tandem cycles" rather than to cycle rickshaws. The character of a cycle rickshaw was treated as materially different from a bicycle or cycle combination because its essential feature is carriage of a person, not self-propulsion. On that interpretation, cycle rickshaws were not taxable under entry 38 at the higher single-point rate.

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Issues: Whether cycle rickshaws fall within entry 38 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 as "cycle combinations" and are therefore taxable at the higher single-point rate.

Analysis: The expression "cycle combinations" was construed in its statutory setting, having regard to the collocation of words in entry 38 and the punctuation and arrangement used in the Schedule. The associated words showed that "cycle combinations" was linked with "tandem cycles" and not intended to extend to cycle rickshaws. The character of a cycle rickshaw was also found to be materially different from that of a bicycle or cycle combination, since its essential feature is not self-propulsion but carriage of a person in the rickshaw.

Conclusion: Cycle rickshaws do not fall within entry 38 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959. The revision petition therefore fails.

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