Wide construction of tariff entry: copper strips fall within the specific entry, not the residuary category.

Copper strips were held to fall within the broad wording of entry 27 in Schedule II Part A to the Gujarat Sales Tax Act, 1969, rather than the residuary entry in Schedule III. The interpretation of the entry was not confined to the specific articles named in it, and the omission of copper strips by name did not require their treatment as residuary goods. Applying the ordinary and metallurgical meanings of the terms, a strip could reasonably be understood within the broader sense of a bar, and the Tribunal erred in treating the distinction as decisive. The separate iron and steel entry did not compel a narrower construction of entry 27.

---

---

Issues: Whether copper strips sold by the assessee were covered by entry 27 of Schedule II Part A to the Gujarat Sales Tax Act, 1969, or were liable to be taxed under the residuary entry in Schedule III.

Analysis: Entry 27 was held to be cast in wide terms and not intended to be exhaustively restrictive merely because specific articles such as bars and rods were mentioned. The earlier interpretation of the same entry had accepted that the enumeration was not confined to a narrow meaning, and the omission of copper strips by name did not justify their automatic placement in the residuary entry. On the ordinary and metallurgical meanings of the words, a strip could reasonably fall within the broader sense of a bar, and the Tribunal had erred in treating the distinction between bars and strips as conclusive. The presence of a separately worded iron and steel entry did not alter the construction of entry 27, because its structure showed a different legislative pattern and did not compel an exhaustive reading.

Conclusion: Copper strips were covered by entry 27 of Schedule II Part A to the Gujarat Sales Tax Act, 1969, and were not liable to be taxed under the residuary entry.

---