Insecticide classification for mosquito mats under sales tax entry upheld, securing single-point levy treatment

Mosquito mats marketed as "Good Knight" were treated as insecticides for sales tax classification under item 66 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959. The Court focused on the true nature of the commodity and held that item 66 covered insecticides and combinations thereof without requiring any minimum percentage of active ingredient. It rejected application of ejusdem generis because the entry expressly referred to insecticides. On that basis, the products were not to be reclassified as multi-point goods and were liable only to single-point levy.

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Issues: Whether mosquito mats marketed as "Good Knight" were classifiable as insecticides under item 66 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 and therefore exigible only to single-point tax.

Analysis: The decisive question was the true nature of the commodity and the scope of item 66, which covered fungicides, herbicides, insecticides, pesticides, rodenticides and combinations thereof. The entry did not prescribe any minimum percentage of active ingredient. The Court accepted that the product, though containing other ingredients, retained the character of an insecticide for taxation purposes. The reasoning also rejected the attempt to apply ejusdem generis, since the entry itself expressly referred to insecticides and their combinations. On that basis, the administrative reclassification as multi-point goods was not accepted.

Conclusion: The mosquito mats were held to fall within item 66 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 and were liable only to single-point levy.

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