Contextual interpretation of tariff entries excludes shoe polish from the exempt class under the Kerala Sales Tax schedule.

A tariff or schedule entry must be read in its textual context and in light of the heading under which it appears, so a general word is confined to goods of the same class as the associated items. On that construction, shoe polish did not fall within entry 72 of the First Schedule to the Kerala General Sales Tax Act, 1963, which covered dyeing, tanning and colouring materials such as paints, colours, lacquers, varnishes, pigments and polishes. The Tribunal's contrary view was held erroneous, and the turnover of shoe polish remained taxable as assessed.

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Issues: Whether shoe polish falls within entry 72 of the First Schedule to the Kerala General Sales Tax Act, 1963, and is therefore exempt as a second sale.

Analysis: Entry 72 appears under the heading "dyeing, tanning and colouring materials" and lists items such as paints, colours, lacquers, varnishes, pigments and polishes. The meaning of "polish" in isolation may be wide enough to include a substance used for polishing, but the word must be read in the context of the heading and the associated items. Construed as a class, the entry covers goods of the same general kind as paints, colours, lacquers, varnishes and similar materials, and not shoe polish. The contextual setting of the entry therefore excludes shoe polish from its scope.

Conclusion: Shoe polish does not fall within entry 72 of the First Schedule to the Kerala General Sales Tax Act, 1963. The Tribunal's view was erroneous, and the turnover of shoe polish remained taxable as assessed.

Ratio Decidendi: A tariff or schedule entry must be interpreted in its textual context and in light of the heading under which it appears, and a general word is confined to goods of the same class as the associated items.

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