Restrictive meaning of "that is to say" in tax classification keeps network items outside the broader entry.

The phrase "that is to say" in a taxing entry is ordinarily restrictive and limits, rather than enlarges, the scope of the preceding general words unless the statutory context shows a contrary intention. Applying that rule, installation cables, outlet or connection modules, patch cords, patch panels, network cards and fibre optic cables were not covered by Entry C.20(ii)(b) of the Karnataka Sales Tax Act, 1957. They were correctly classified under Part E of the Second Schedule, and the classification was upheld.

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Issues: Whether installation cables, outlet or connection modules, patch cords, patch panels, network cards, fibre optic cables and similar items were covered by Entry C.20(ii)(b) of the Second Schedule to the Karnataka Sales Tax Act, 1957, or were correctly classified under Part E of that Schedule.

Analysis: The exclusion turned on the meaning of the phrase "that is to say" in the entry. The Court applied the settled rule that such words are words of limitation and must receive a restrictive construction, so as not to enlarge the scope of the preceding general words. On that construction, the specified items were not brought within Entry C.20(ii)(b). The conclusion was consistent with the earlier rulings relied upon, which treated the phrase as limiting rather than expanding the description of goods.

Conclusion: The items in question were not covered by Entry C.20(ii)(b) and were correctly held to fall in Part E of the Second Schedule to the Karnataka Sales Tax Act, 1957, against the assessee.

Final Conclusion: The classification adopted below was upheld and the appeals failed.

Ratio Decidendi: The phrase "that is to say" in a taxing entry is ordinarily restrictive and limits, rather than enlarges, the scope of the preceding words, unless the statutory context clearly indicates otherwise.

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