Meaning of “Varnish”

Case Name : Dr. Beck & Co. India Ltd. Vs. ITO

Citation : [1984] 10 ITD 145 (BOM. – TRIB.)

Court : ITAT-Bombay

Schedule : ELEVENTH SCHEDULE

Meaning : The expression ‘varnish’ should also be read along with the other items in item 26. It would be seen that pigments, colours, paints, etc., Form one common genera, i.E., Articles used for decoration or protection.

The expression ‘varnish’ found in the item should be, therefore, restricted to that type of varnish which are used only for decoration or hiding surfaces. There are large number of products which come under the head ‘varnish’.

The principle noscitur a sociis requires be to restrict the meaning of the word ‘varnish’ and hold that it will cover only such type of varnishes which will be analogous with the rest of the words, i.E., Which will be analogous with pigments, colours and paints. Herein comes the requirement to which the varnish is put.

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