Noscitur a sociis narrows "coated paper" exclusion under the excise notification, preserving concessional treatment for printing paper.

The proviso to Notification No. 25/84 was construed narrowly by applying noscitur a sociis: the expression "coated paper" took colour from neighbouring exclusions such as cigarette tissue, glassine paper, grease proof paper, and low-weight paper, all of which shared an industrial character. On that reading, the exclusion was confined to coated paper used for industrial purposes and did not extend to coated varieties of printing and writing paper. The assessee was therefore entitled to the concessional excise rate, and the exclusion of art paper and chromo paper as coated paper was unsustainable.

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Issues: Whether the expression "coated paper" in the second proviso to Notification No. 25/84 excluded all coated varieties of printing and writing paper, or only coated paper used for industrial purposes.

Analysis: The notification granted concessional excise rates to paper and paper boards made from unconventional raw materials, but denied the concession to specified categories of paper in the proviso. The surrounding excluded items, namely cigarette tissue, glassine paper, grease proof paper, and paper of a substance not exceeding 25 grammes per square metre, indicated a common industrial character. Reading the proviso as a whole and in the light of the object of the notification, the broader expression "coated paper" was held to take colour from its associates. The Court applied the principle of noscitur a sociis and accepted that the restriction was intended for coated paper of industrial use, not for coated varieties of printing and writing paper.

Conclusion: The assessee was entitled to the concessional rate under Notification No. 25/84, and the exclusion of art paper and chromo paper as coated paper was unsustainable.

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