Restricted meaning of "packed" under sales tax entry excludes mere resale in gunny bags without dealer packing.

Item 103 of the Tamil Nadu General Sales Tax Act was held to apply only where the goods satisfied all cumulative conditions, including that they were tinned, canned, bottled or packed and sold under a registered brand name. The word "packed" was given a restricted meaning by noscitur a sociis, taking colour from the accompanying words and covering packing done for preservation, transport or sale, not mere resale in the same gunny bags in which the goods were purchased. As the dealer only bought sago and tapioca products in gunny bags and resold them without packing, the statutory condition was not met and the higher levy did not apply.

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Issues: Whether sago and tapioca products sold in gunny bags without any packing done by the assessee could be treated as goods that are "packed" under item 103 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, so as to attract tax at the specified rate.

Analysis: Item 103 applied only where the goods answered all the stated conditions, including that they were tinned, canned, bottled or packed, sold under a registered brand name, and did not fall under item 24. The expression "packed" was construed in context with the accompanying words "tinned, canned or bottled" and was given a restricted meaning by applying the principle of noscitur a sociis. On that construction, the word covered packing done for preservation, transport and sale, and not mere wrapping, parcelling or sale in the same gunny bags in which the goods were purchased. Since the assessee only bought the goods in gunny bags and resold them in the same condition with a brand name affixed, clause (a) was not satisfied.

Conclusion: The goods did not fall within item 103, and the turnover was not liable to tax on that basis.

Ratio Decidendi: In item-based sales tax entries, a word such as "packed" takes colour from associated words in the entry and, unless the stipulated cumulative conditions are satisfied, mere sale in gunny bags without packing by the dealer does not attract the higher levy.

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