Taxing entry interpretation rejects ejusdem generis restriction and confirms cloth bags fall within the specific schedule entry.

Cloth bags prepared from textile or handloom fabrics and sold within the prescribed price limit were held to fall within entry 51 of Schedule I to the Gujarat Sales Tax Act, 1969, rather than the residuary entry 13 of Schedule III. The court held that the phrase "ready-made garments and articles" was clear, and the word "articles" was not confined by ejusdem generis to goods of domestic or personal use. It refused to add restrictive words not found in the text, noting that the specific exclusions in the entry showed no further implied limitation. Any reasonable ambiguity in the taxing entry was also required to be resolved in favour of the assessee.

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Issues: Whether cloth bags prepared from textile or handloom fabrics and sold at a price not exceeding the prescribed limit fell within entry 51 of Schedule I to the Gujarat Sales Tax Act, 1969, or whether they were to be treated as residuary goods under entry 13 of Schedule III.

Analysis: The entry used the expression "ready-made garments and articles" followed by the qualifying words "prepared from any textile or handloom fabrics" and then expressly excluded hosiery goods and certain other articles. The restrictive reading adopted by the Tribunal proceeded on the assumption that the word "articles" must take colour from "ready-made garments" and be confined to goods of domestic or personal use. The Court held that the expression "articles" did not belong to the same genus as "ready-made garments" and therefore the doctrine of ejusdem generis had no application. The words of the entry were clear and unambiguous, and there was no warrant for adding limiting words not found in the statute. The express exclusion of specified items after the word "articles" also showed that no further implied restriction was intended. Even otherwise, where two reasonable constructions were possible, the one favourable to the assessee was required to be adopted.

Conclusion: The disputed cloth bags were covered by entry 51 of Schedule I and were not liable to be treated as residuary goods under entry 13 of Schedule III. The finding was in favour of the assessee.

Ratio Decidendi: Where the language of a taxing entry is clear, the court cannot invoke ejusdem generis to read in a restrictive meaning that is not supported by the statutory text, and any reasonable ambiguity must be resolved in favour of the assessee.

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