Associated-words classification principle places mineral turpentine under the general petroleum and mineral oil entry.

Mineral turpentine was held to fall within the general entry for petroleum products and mineral oils, not the clustered entry for turpentine oil with dyes, paints, varnishes, lacquers, enamels, glue, paint-brush and sandpaper. The court applied the ejusdem generis or associated-words principle to read entry 25 in the context of the grouped commodities, and found that the assessee's mineral-origin by-product had no connection with that class of goods. Entry 39, being the broader petroleum and mineral oil entry, therefore governed the classification.

---

---

Issues: Whether mineral turpentine falls under entry No. 25 of Part II of Schedule II to the M.P. General Sales Tax Act, 1958 or under entry No. 39 of Part II of Schedule II to the M.P. General Sales Tax Act, 1958.

Analysis: Entry No. 25 groups turpentine oil with dyes, paints, varnishes, lacquers, enamels, glue, paint-brush and sandpaper, so the associated words limit its scope to the class of commodities used in that context. Mineral turpentine sold by the assessee was found to be a by-product of refined crude oil and therefore of mineral origin. It was not shown to have any connection with the commodities grouped in entry No. 25. Entry No. 39, on the other hand, is a general entry covering all kinds of petroleum products and mineral oils, and the mineral turpentine in question answered that description.

Conclusion: Mineral turpentine falls under entry No. 39 of Part II of Schedule II to the M.P. General Sales Tax Act, 1958 and is not taxable under entry No. 25.

Ratio Decidendi: Where a commodity is placed in a group of associated goods, its meaning is controlled by the company it keeps, and a mineral-origin product falling within a general petroleum and mineral oil entry is classified under that general entry rather than a clustered specific entry.

---