Ordinary meaning of "perfumery" covered dhoop and agarbatti, confirming sales tax liability under the relevant entry.

Dhoop and agarbatti were treated as falling within the ordinary meaning of "perfumery" under Schedule A to the Punjab General Sales Tax Act, 1948, because they are substances capable of emitting agreeable odour. That construction supported tax liability at 10 per cent for the relevant assessment year. A later amendment expressly referring to "perfumery including dhoop and agarbatti" was viewed as confirming, rather than changing, the original interpretation. The stated ratio is that tariff or sales tax entries are read according to their ordinary commercial and dictionary meaning, and a subsequent clarifying amendment may reinforce that construction.

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Issues: Whether dhoop and agarbatti fell within the expression "perfumery" under Schedule A to the Punjab General Sales Tax Act, 1948 so as to attract tax at 10 per cent for the assessment year 1978-79.

Analysis: The relevant entry in Schedule A used the expression "perfumery", and the Court applied the ordinary meaning of that term. Reliance was placed on the settled interpretation that dhoop and agarbatti are substances capable of emitting agreeable odour and therefore answer the description of perfumery. The subsequent amendment adding an express entry for "perfumery including dhoop and agarbatti" was treated as supporting, rather than contradicting, that interpretation for the assessment in question.

Conclusion: Dhoop and agarbatti were held taxable as perfumery at the rate of 10 per cent, and the challenge to the assessment failed.

Final Conclusion: The assessment of tax on dhoop and agarbatti was upheld and the writ petition was dismissed.

Ratio Decidendi: An item may fall within a tariff or sales tax entry according to its ordinary commercial and dictionary meaning, and an express later amendment clarifying the same category may confirm that construction.

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