Broad tax entries include glass and plastic bangles; restrictive interpretation rejected, and entry tax levy upheld.

Clear and wide tariff entries covering "all articles made of glass" and "articles made from all kinds of plastics" were held to include glass bangles and plastic bangles, making them liable to entry tax. The court rejected a restrictive reading based on noscitur a sociis because the statutory language was plain and deliberately expansive. It also rejected the common parlance test, holding that such a test is inappropriate where the text is unambiguous and uses broad terms. The levy on the bangles was upheld and the order quashing the assessments and clarification was set aside.

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Issues: (i) Whether glass bangles and plastic bangles fell within the entries covering glass sheets and all articles made of glass, and plastic sheets, granules and articles made from all kinds of plastics, so as to attract entry tax; (ii) Whether the principle of noscitur a sociis and the common parlance test could be applied to restrict the scope of those entries.

Issue (i): Whether glass bangles and plastic bangles fell within the entries covering glass sheets and all articles made of glass, and plastic sheets, granules and articles made from all kinds of plastics, so as to attract entry tax.

Analysis: The entries were held to be clear and unambiguous. The use of the words "and" and "all articles made of glass" and "articles made from all kinds of plastics" showed a legislative intention to levy tax not only on glass sheets and plastic sheets but also on finished articles made of glass or plastic. The expression was wider than "glassware" and could not be read down by reference to cases dealing with that narrower entry. The absence of glass bangles and plastic bangles from the exempted list reinforced the conclusion that they were taxable.

Conclusion: Glass bangles and plastic bangles were held to fall within the taxable entries and were liable to entry tax.

Issue (ii): Whether the principle of noscitur a sociis and the common parlance test could be applied to restrict the scope of those entries.

Analysis: Noscitur a sociis was found inapplicable because the statutory language was plain and the wider words had been deliberately used to enlarge the scope of the entries. The common parlance test was also rejected because that test applies where the statutory expression is undefined and ambiguous, whereas the present entries used broad and definite language covering articles made of glass and plastic. Authorities dealing with the narrower term "glassware" were distinguished on that basis.

Conclusion: Neither noscitur a sociis nor the common parlance test could be used to exclude the bangles from the scope of the entries.

Final Conclusion: The levy of entry tax on glass and plastic bangles was upheld, and the judgment quashing the assessments and clarification was set aside.

Ratio Decidendi: Where statutory entries are expressed in clear and wide terms, a restrictive construction based on noscitur a sociis or common parlance is impermissible, and articles plainly covered by the wording remain taxable.

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