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Issues: Whether sales of rubber used for retreading of tyres fall within entry 36 of Part II of Schedule II of the M.P. General Sales Tax Act, 1958 as "other articles made of rubber".
Analysis: The expression "other articles made of rubber" was construed in its ordinary and comprehensive sense. The words "article" and "rubber" were not defined in the Act, so the Court referred to their ordinary meaning and held that the entry was intended to cover all kinds of articles made of rubber, including raw material as well as finished goods. The specific items named in the entry, followed by the wider expression "other articles made of rubber", showed a legislative intent to adopt an expansive coverage rather than a restricted one. A commodity could fall in the residuary entry only if no specific entry in the Schedule applied.
Conclusion: Sales of rubber used for retreading tyres are covered by entry 36 of Part II of Schedule II and are taxable under that entry, not under the residuary entry.
Ratio Decidendi: Where a taxing entry uses broad words such as "other articles made of rubber" and the statute contains no restrictive definition, the expression must be given its ordinary wide meaning so as to include all commodities made of that material, unless clearly excluded by the Act.