JUDGMENT ASHOK BHAN, J. - Assistant Commissioner of Commercial Taxes and another have directed these appeals against the order dated March 15, 1995 passed by a single Judge in W.P. Nos. 32727, 32728, 32753, 32754 and 16977 to 16981 of 1994, (Reported as Brindavan Bangle Stores v. Assistant Commissioner of Commercial Taxes [1996] 101 STC 235 (Kar)) wherein the petitions filed by the respondents have been allowed and the assessment orders, annexures "A" and "B" for the years 1992-93 and 1993-94 made by appellant No. 1 and the clarification No. KTEG. CLR. CR. 36 of 1992-93 dated July 21, 1992 issued by appellant No. 2, annexure "E", have been ordered to be quashed. 2. Respondents in these appeals are dealers in glass and plastic bangles. In the writ petitions filed by them, they had challenged the imposition of entry tax on glass and plastic bangles under the Karnataka Tax on Entry of Goods into Local Areas for Consumption, Use or Sale Therein Act, 1979 (hereinafter referred to as "the Act"). Clarification issued by appellant No. 2, annexure "E", clarifying that entry tax was exigible on glass and plastic bangles was also challenged by them. 3. Section 3(1) provides that there shall be levy and collect tax on entry of any goods specified in the First Schedule into a local area for consumption, use or sale therein at such rates which may be prescribed by the State Government by issuance of a notification. Different dates and different rates could be specified in respect of different goods or different classes of goods for different local areas. Government issued Notification No. FD. 69 CET 92 (i) dated April 30, 1992. A list was appended to the notification containing entries 30 and 54 which read as under : "Entry 30 : Glass sheets and all articles made of glass. 2 per cent Entry 54 : Plastic sheets, granules and articles made from all kinds 2 per cent." of and all forms of plastics including articles made of polypropylene, polyesterene and the like materials. These entries correspond to entries 39 and 70 to the First Schedule of the Act. But for convenience sake we shall refer to them as entries 30 and 54 in this judgment. 4. These entries correspond to entries 39 and 70 to the First Schedule of the Act. But for convenience sake we shall refer to them as entries 30 and 54 in this judgment. 4. Assessment orders, annexures "A" and "B", were based on the Commissioner's clarification dated July 21, 1992, annexure "E" whereby it was informed that plastic and glass bangles attract entry tax at the rate of 2 per cent with effect from May 1, 1992 as per entry 30 and entry 54 of the list appended to the Government Notification No. FD 69 CET 92 dated April 30, 1992. 5. According to the respondents glass and plastic bangles were not covered under entry 30 and entry 54 as stood at the relevant point of time and further bangles (glass and plastic) were not included in entries 30 and 54. 6. Learned single Judge accepted the plea raised by the respondents and held that the expression "glass sheets or plastic sheets and articles made of glass or plastic" in the relevant entry convey a meaning that they take colour from each other, i.e., the more general is restricted to a sense analogous to less general and the Legislature did not intend to include plastic and glass bangles in entry 30 and entry 54. Following the principle of interpretation, "noscitur a sociis" and relying upon a judgment of the Supreme Court in the case of State of Bombay v. Hospital Mazdoor Sabha reported in AIR 1960 SC 610 , held that the clarification made by the Commissioner was totally inept and quashed the same. Further, the learned single Judge quashed the levy of tax on plastic and glass bangles in the impugned order of assessments. The writ petitions were allowed. Aggrieved against which the present appeals have been filed. 7. Mr. D'Sa, learned Government Advocate, has argued on behalf of the appellants that entries 30 and 54 are very clear and unambiguous. The words of these two entries being clear and unambiguous, the question of interpretation of the same in any other meaning except giving a true meaning as they stand does not arise. The glass sheets being nothing but raw materials required for manufacture of articles made of glass, the second part of the said entry relates to finished product made of glass sheets as also articles made of glass. The glass sheets being nothing but raw materials required for manufacture of articles made of glass, the second part of the said entry relates to finished product made of glass sheets as also articles made of glass. The same analogy is applicable in so far as entry 54 is concerned. The word "and" occurring in entries 30 and 54 assumes importance in the circumstances of the case making intention of the Legislature clear that the Legislature intended to levy tax both on glass sheets as also finished products of glass, which finds a place in the latter half of the entry. The rule of construction "noscitur a sociis" applied by the learned single Judge to the entries in question was not systematical because the words used by the Legislature were clear and free from any ambiguity. As against this, the counsel appearing for the respondents supported the judgment of the learned single Judge and relied upon the judgment of the Kerala High Court in Deputy Commissioner of Sales Tax (Law), Board of Revenue (Taxes), Ernakulam v. K. Ummul Kulsu [1994] 92 STC 450, of the Orissa High Court in the case of State of Orissa v. Janata Medical Stores [1976] 37 STC 33, of the Andhra Pradesh High Court in Mahalakshmi Traders v. Deputy Commercial Tax Officer (M & G), Visakhapatnam [1983] 53 STC 263 and in Shah Pratap Chand Kantilal & Co. v. State [1986] 63 STC 312 and of the Karnataka High Court in Kishopilal Radheysham v. Deputy Commissioner of Commercial Taxes, Bangalore City Division [1982] 50 STC 19, to canvass the proposition that while interpreting items of statutes like the Sales Tax Acts, resort should be had not to the scientific and technical meaning of the terms or expressions used, but to their popular meaning, that is to say, that the meaning attached to them by those dealing in them. In the absence of any definition, the meaning of the term in common parlance or commercial parlance has to be adopted. According to him the glass bangles or glass could not be termed as glassware, i.e., article made of glass because in common or commercial parlance they were treated as different items and were understood as distinct and different than the glassware. 8. According to him the glass bangles or glass could not be termed as glassware, i.e., article made of glass because in common or commercial parlance they were treated as different items and were understood as distinct and different than the glassware. 8. After hearing the counsel for the parties at length with great respect to the learned single Judge we are of the opinion that the learned single Judge has erred in following the rule of construction "noscitur a sociis" to the facts and circumstances of this case. As pointed out by the Supreme Court in State of Bombay v. Hospital Mazdoor Sabha AIR 1960 SC 610 , according to Maxwell "nocitur a sociis" means that when two or more words which are susceptible of analogous meaning are coupled together they are understood to be used in their cognate sense. They take as it were their colour from each other, that is, the more general is restricted to a sense analogous to a less general. In para 9 it has been observed : "We are not impressed by this argument. It must be borne in mind that noscitur a sociis is merely a rule of construction and it cannot prevail in cases where it is clear that the wider words have been deliberately used in order to make the scope of the defined word correspondingly wider. It is only where the intention of the Legislature in associating wider words with words of narrower significance is doubtful, or otherwise not clear that the present rule of construction can be usefully applied. It can also be applied where the meaning of the words of wider import is doubtful; but, where the object of the, Legislature in using wider words is clear and free of ambiguity, the rule of construction in question cannot be pressed into service." 9. Counsel for the respondents contended that dictionary meaning of "glassware" is "articles made of glass" and therefore the phrase "articles made of glass" would mean "glassware". This contention cannot be accepted to interpret the entry "articles made of glass". Judgments relied upon by the counsel for the respondents do not take his case further and we would discuss each one of them separately. 10. This contention cannot be accepted to interpret the entry "articles made of glass". Judgments relied upon by the counsel for the respondents do not take his case further and we would discuss each one of them separately. 10. In State of Orissa v. Janata Medical Stores [1976] 37 STC 33, the question involved before the Orissa High Court whether thermometers, lactometers, syringes, eye-wash glasses and measuring glasses which were articles made of glass would be termed as "glassware" was rejected. The relevant entry in the Schedule read "glassware". While holding that thermometers, lactometers, eye-wash glasses, syringes and measuring glasses did not come within the meaning of glassware, it was observed : "'Glassware' as understood from the Shorter Oxford English Dictionary is 'articles made of glass'. In popular sense glassware would ordinarily refer to articles made of glass. In general use, when glassware is referred to one's mind, thermometers, lactometers, syringes or eye-wash glasses or even measuring glasses do not occur. A general merchant dealing in glassware ordinarily does not deal in these articles. These are articles which are normally available in a medical shop such as that of the assessee before us. Thermometers and lactometers and also syringes are not only made of glass but there are other components. Though their bodies may be of glass, the additional materials of non-glass origin therein which really make them marketable and goods of utility have a predominant place. Therefore, they do not strictly come within the common parlance meaning of glassware. Undoubtedly, eye-wash glass and measuring glass are made of glass, but when one refers to glassware, these specialised materials are not understood to be glassware as such." A reading of the judgment shows the entry was glassware and in the context it was held that thermometers, lactometers, syringes, eye-wash glasses and measuring glasses though made of glass, the additional material of non-glass origin therein made the real difference and they made marketable and goods of utility different than the glassware. 11. In Shah Pratap Chand Kantilal & Co. v. State [1986] 63 STC 312 (AP) again the entry was "glassware" and the question was whether "glass marbles" could be termed as "glassware". The contention was negatived by holding that the purpose, utility and the functions of the glass marbles are wholly different from glassware and they are not sold generally by those who deal in glassware. v. State [1986] 63 STC 312 (AP) again the entry was "glassware" and the question was whether "glass marbles" could be termed as "glassware". The contention was negatived by holding that the purpose, utility and the functions of the glass marbles are wholly different from glassware and they are not sold generally by those who deal in glassware. The glass marbles are not sold by those who generally deal in glassware and therefore the sale of glassware would not fall within entry 123 of the First Schedule to the Act. 12. In Mahalakshmi Traders v. Deputy Commercial Tax Officer (M & G), Visakhapatnam [1983] 53 STC 263 (AP), the entry in the Schedule was glassware and the question posed was as to whether the bangles would be termed as glass-ware, it was held that bangles were general goods and not glassware. 13. In Deputy Commissioner of Sales Tax (Law), Board of Revenue (Taxes), Ernakulam v. K. Ummul Kulsu [1994] 92 STC 450 (Ker) the entry was "glass-ware" and the question was whether empty bottles and phials could be covered under entry "glassware". It was held that in the absence of a definition in the Act the popular meaning or the meaning attached to glassware by persons who deal in that item has to be resorted to. Glassware as ordinarily understood is something to do with tableware like glass tumblers, glass dishes, plates, etc. Since the glass bottles and phials are not ordinarily available in a glassware shop, empty bottles and phials could not be brought to tax as sale of glassware under entry 111 of the First Schedule to the Act. 14. In Kishorilal Radheysham v. Deputy Commissioner of Commercial Taxes [1982] 50 STC 19, this Court held that glass marbles could not be termed as glassware. Common parlance test was applied in this case as well. It was held that in the absence of definition of "glassware" in the Act, definition of common parlance was attracted. It was held that though marbles were made by glass but in common parlance they were understood and treated as sport and plaything and not glassware. The glass marbles were not sold generally by any dealer dealing in glassware. Glass marbles therefore could not be taxed in the turnover of the assessee under entry 109 as glassware. 15. A reading of these judgments shows that entries there were "glassware". The glass marbles were not sold generally by any dealer dealing in glassware. Glass marbles therefore could not be taxed in the turnover of the assessee under entry 109 as glassware. 15. A reading of these judgments shows that entries there were "glassware". The question is whether the specialised items like thermometers, lactometers, wind screen, rear screen, syringes, eye-wash glasses, empty bottles, or phials could be tenned as "glassware". In respective Schedules to the Act in those cases the entry was restricted to "glassware" whereas the present entry is "all articles made of glass" and "articles made from all kinds of and all forms of plastic". Entry in the Act before us is much wider and would include any article made of glass or plastic for the purpose of levy of entry tax under the Act. There is no reason to read down the entry "article made of glass" to "glassware". The definition has to be given its widest meaning because it projects an inclusive definition. In the judgments relied upon by the counsel for the respondent, glassware was restricted to its dictionary meaning whereas articles made of glass is wider in its meaning. Involved argument of the learned counsel for the respondent that since the entry "glassware" was read as "articles made of glass" therefore the entry "article made of glass" has to be read as "glassware", cannot be accepted. Dictionary meaning of "glassware" may be articles made of glass but the reverse may not be true as the import of the entry "articles made of glass" and "articles made of all kinds of plastics" in much wider. The Legislature by using the words of wider import which are clear and free of any ambiguity, has made its intentions clear and the rule of construction applied by the learned single Judge would not be applicable to the facts and circumstances of the case. 16. By using the words "glass sheets" and "all articles made of glass" separately by putting the word "and" in between, the Legislature has made its intentions clear. The words used are not ambiguous and it cannot be said that one is more general and the other is less general thereby restricting the meaning of less general to a sense analogous to the word which is more general. It clearly states that "glass sheets" and "all articles made of glass" are liable to be taxed. The words used are not ambiguous and it cannot be said that one is more general and the other is less general thereby restricting the meaning of less general to a sense analogous to the word which is more general. It clearly states that "glass sheets" and "all articles made of glass" are liable to be taxed. Similarly in entry 70 the words used are plastic sheets, granules, articles made from all kinds of and all forms of plastics including ..... The intention of the Legislature was to include glass sheets and plastic sheets which are used for manufacture of articles made out of glass sheets and plastic sheets which are used for manufacture of articles made out of glass and plastics as well as all articles made of glass or from any kind and all kinds of plastics to be taxed at the entry point under the Act. Glass sheets or plastic sheets is not a principal part of the entry. By making an entry all articles made of glass and articles made from all kinds and all forms of plastics, the Legislature clearly spelt out its intention to levy entry tax on glass sheets as also articles made of glass and on the same analogy plastic sheets and articles made from all kinds and all forms of plastics. The entries are clear and unambiguous and interpreting the same in a different manner is not possible. Legislature has clearly spelt out its intention by using the word "and" in the said entries. Legislature intended to levy tax both on glass sheets/plastic sheets as also finished products of glass/plastics which finds a place in a latter half of the entry. 17. Common parlance test would not be applicable in the present case. In the cases relied upon by the assessees, the entry being glassware and in the absence of any definition in the Act of the word "glassware", the popular meaning or the meaning attached to glassware by persons who dealt in that item was resorted to. The present entry being articles made of glass/plastic being clear, the common parlance test or the popular meaning attached to the articles would not be applicable. 18. The present entry being articles made of glass/plastic being clear, the common parlance test or the popular meaning attached to the articles would not be applicable. 18. It may be relevant to state at this stage that during the relevant point of time as per section 3(6) of the Act, Second Schedule was introduced, whereby certain commodities exempted from levy of entry tax, have been specified in the said Schedule. Neither glass bangles-nor plastic bangles finds a place in Schedule II. 19. For the reasons stated above, the appeals are accepted. Order of the learned single Judge is set aside and orders, annexures "A", "B" and "E", are upheld. Parties shall bear their own costs. Appeals allowed.