Judgment :- C.N. Ramachandran Nair, J. The question arising in both the Tax Revisions filed by the assessee is about the classification of their product “water filter cum purifier” sold under the brand name “Aqua Guard”. While the case of the assessee is that the item is electrical apparatus, and therefore falls under Entry 48 of the First Schedule to the KGST Act during the relevant year, the case of the department is that the item is “water filter” falling under Entry 104 of the First Schedule to the Act. Even though the rate of tax provided under the First Schedule for both the Entries is the same, namely, 12.5 per cent, the issue cropped up because of the reduction in rate of tax granted by the Government in respect of electrical goods under Government Notification reducing the rate from 12.5 per cent to 10 per cent. 2. In order to appreciate the contentions, we have to refer to both the Entries which are extracted hereunder: Entry 48: Electrical goods (other than those specifically mentioned in this schedule), instruments, apparatus, appliances, grinders, cooking ranges, hot plates, water heaters and other domestic electric appliances and apparatus including fan & lighting bulbs, electrical earthen-ware, porcelain and all other accessories and component parts, either sold as a whole or in parts. At the point of first sale in the State by a dealer who is liable to tax under under Sec.5 12.5% Entry 104: Pressure cooker, cook and serve ware to keep food warm casseroles, water filters and similar home appliances not coming under any other entry in this Schedule or in the Fifth Schedule. At the point of first sale in the State by a dealer who is liable to tax under Sec. 5 12.5% 3. Before considering the appropriate Entry under which the item falls, we have to examine the nature of operation of the product sold by the petitioner. Petitioner’s product obviously serves as a water filter and this is one of the main functions it achieves. However, in addition to filtering water, whereunder undissolved impurities removed, water is exposed to ultra violet light which removes bacteria and other micro living organisms and germs. Petitioner has given detailed description of the equipment which contains two chambers, one is meant for filtering water, and in the other chamber filtered water is exposed to ultra violet radiation for further purifying filtered water. Petitioner has given detailed description of the equipment which contains two chambers, one is meant for filtering water, and in the other chamber filtered water is exposed to ultra violet radiation for further purifying filtered water. Respondents have no controversy about the process involved in the petitioner’s machine which is a programmed and electrically operated water purifier used by large number of consumers. The case of the petitioner is that water filters referred to in Entry 104 are only common water filters known in the market which do not require any electricity for their operation. These are water filters with porous candle as a filter on poly propelline pad as filter media. Even though the water obtained from water filter is generally free from impurities, it may not be fully from bacteria and other germs. On the other hand, the water obtained from petitioner’s product is not only filtered, but is exposed to ultra violet radiation process which is a well known process used to destroy bacteria and all other kinds of germs. Therefore obviously petitioner’s product is not a water filter pure and simple. Special Government Pleader submitted that the essential function in the petitioner’s product also is filtering of water and whatever be the subsequent treatment of the water in the very same machine, the same continues to be water filter falling under Entry 104. In support of his contention, counsel for the petitioner also relied on the decision of the Supreme Court in Pradeep Aggarbatti v. State of Punjab, 1997 AIR SCW 4132 and contended that applying the principle of noscitur a ciis the item sold by the petitioner should be brought under entry 48 along with other electrical appliances. It is to be noted that none of the home appliances referred to in Entry 104 is electrically operated. On the other hand Entry 48 covers all electrical goods including home appliances like grinders, cooking ranges, etc. We find that Entry 48 is residuary entry for all electrical goods and it takes in every equipment operated with electricity other than those specifically mentioned elsewhere in the Schedule. It is pertinent to note that large number of home appliances operated with electricity are brought under Entry 48. In other words, Legislature has classified home appliances into two classes, one, electrically operated and the other not operated with electricity. It is pertinent to note that large number of home appliances operated with electricity are brought under Entry 48. In other words, Legislature has classified home appliances into two classes, one, electrically operated and the other not operated with electricity. In this view of the matter, we feel, by applying the rule of noscitur a ciis we have to treat electrical water filter cum purifier sold by the petitioner as falling under Entry 48 of the First Schedule to the Act. Even if the argument of special Government Pleader that water filters operated with electricity also will be covered by Entry 104 under the head “water filters” is accepted, still we are inclined to hold that petitioner’s product will fall under Entry 48 because it is not pure water filter, but it is as much a water filter as it is a water purifier, that too with the aid of electricity. It is to be noted that petitioner’s equipment is electrically operated and without the aid of power, it cannot work. It has electronic regulator for regulating flow of water after retaining it within the machine for sufficient time for exposure to ultra violet light for removing bacteria and other germ. For the foregoing reasons, we hold that the item is electrical goods falling under Entry 48 of the First Schedule to the KGST Act and we consequently reverse the finding of the Tribunal and allow the Tax Revisions filed by the assessee.