Contextual reading of tariff entries limits sanitary pipe fittings coverage, leaving rubber hoses taxable under the residual rate.

Tariff entries must be read in context, and wider words may be confined by associated words indicating the class of goods intended to be covered. On that construction, the expression covering "all types of sanitary goods and fittings and all types of pipes and pipe fittings" applied to pipes and fittings meant for sanitary use. Rubber hose pipes, not ordinarily used for sanitary purposes and not articles fitted or fixed to a building in the relevant sense, did not fall within the specific entry. They therefore attracted the residual category and were taxable at the general rate rather than the higher specific rate.

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Issues: Whether rubber hoses were covered by the expression "all types of sanitary goods and fittings and all types of pipes and pipe fittings" in the relevant notifications, or were taxable only at the general rate under the residual entry.

Analysis: The expression "all types of pipes and pipe fittings" had to be read in its setting with the associated words "all types of sanitary goods and fittings". On that construction, the entry covered pipes and fittings meant for sanitary purposes. Rubber hose pipes are not ordinarily used for sanitary purposes and are not articles fitted or fixed to the floor or walls of a building in the sense understood for fittings. Since the hoses did not fall within the specific entries and were not shown to be covered by any other entry, they fell within the residual category.

Conclusion: Rubber hoses were not covered by the specific entry and were taxable at the general rate of 6 per cent, not at 10 per cent.

Ratio Decidendi: A tariff entry must be construed in its context, and where words of wider amplitude follow words indicating a specific class, the wider words may be limited by the associated words and the nature of the goods intended to be covered.

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