Judgment :- 1. The assessee is in revision questioning the correctness of the order passed by the Karnataka Appellate Tribunal dated 29.4.2008 in STA No. 587/2003 whereunder appeal filed by the assessee questioning the order of the Joint Commissioner of Commercial Taxes (Appeals) City Division III, Bangalore dated 10.12.2002 came to be affirmed and the appeal of the assessee came to be dismissed. 2. This Court by order dated 31.3.2009 has admitted the above revision for considering the following questions of law: “i) Under the facts and circumstances of the case the Hon’ble Tribunal is right in holding that the petitioner products namely adhesive tapes, cotton ropes, wadding rolls, brass pins, PM pins fall under general entry i.e., under Section 5(1) of the KST Act. 1957 taxable at 10% and not under Sl.No. I-A Part-T of Second Schedule as tailoring materials taxable at 4%; and ii) Under the facts and circumstances of the case, the Hon’ble Tribunal is right in holding that the petitioner products namely knitted fabric and canvas made of cotton falls under entry 7-A of Part-T of Second Schedule of the KST Act 1957 taxable at 2% and not under entry 3 of V Schedule of the KST Act, 1957 as exempted goods.” However, the learned Counsel for the petitioner during the course of his submission has fairly submitted that he would not press question No.(ii) for adjudication and would restrict his submission only to question No.(i). 3. The facts in brief lending to the filling of this revision petition are as under: For the assessment year 1998-99, assessee filed annual return and on verification of the books of accounts the Assessing Officer passed an order of assessment on 30.11.2001 and raised a demand for tax thereunder. The assessee being aggrieved by the said order preferred an appeal under Section 20(5) of the KST Act, 1957 (hereinafter referred to as ‘the Act’) before the Joint Commissioner of Commercial Taxes (Appeals), City Division-III Bangalore in KST AP No.337/2001-02/1998-99. The said appeal came to be dismissed by order dated 10.12.2002. The assessee pursued his claim before the Second Appellate Authority viz., Karnataka Appellate Tribunal, Bangalore in STA No.587/2003 whereunder orders passed by the Assessing Officer and as confirmed by the First Appellate Authority came to be questioned. The said appeal came to be dismissed by order dated 10.12.2002. The assessee pursued his claim before the Second Appellate Authority viz., Karnataka Appellate Tribunal, Bangalore in STA No.587/2003 whereunder orders passed by the Assessing Officer and as confirmed by the First Appellate Authority came to be questioned. The contention put forward by the assessee before the Tribunal was that items “self adhesive tapes, cotton ropes, wadding rolls, brass pins and P.M.Pins, which are used as tailoring materials would fall under Part-T Item No.1-A of Schedule II of the Act and as such, it was contended that it is to be taxed at the rate of 4% and not at the rate of 10% bringing it within the residuary clause and charging it under Section 5(1) of the Act. This contention of the assessee did not find favour with the Appellate Tribunal and as such appeal came to be dismissed by the tribunal by its order dated 29.4.2008 and this order is questioned by the assessee in the present revision petition. 4. Heard Sri Surya Kanth, learned Counsel for the petitioner/assessee and Smt. Sujatha, learned Additional Government Advocate appearing on behalf of the respondent/revenue. 5. It is the contention of Sri Surya Kanth that authorities erred in classifying the goods in question viz., “self adhesive tapes, cotton ropes, wadding rolls, brass pins and P.M.Pins” under the residuary clause and he contends that the same would fall squarely within the Entry I-A Part-T of Schedule II of the Act. He would submit authorities erroneously interpreted the entry and would contend that there cannot be any dispute that these items are falling under the head of ‘tailoring materials’. He would specifically draw the attention of this Court to the words used in the entry viz., Entry 1-A [the words ‘namely’] and contended that it is only illustrative and should not be construed as exhaustive. He would also submit that legislature has subsequently added other items also viz., Horn buttons, Indent hooks/Eyes, jean buttons, knitting pins. Long stick kits. M.S. Coated buttons/Stars, Zip fastness, Zippers, Cuffinks, Crochet hooks by Act 4/2009 with effect from 1.4.1999 which itself would demonstrate that Entry 1A is illustrative and not exhaustive. He would also submit that legislature has subsequently added other items also viz., Horn buttons, Indent hooks/Eyes, jean buttons, knitting pins. Long stick kits. M.S. Coated buttons/Stars, Zip fastness, Zippers, Cuffinks, Crochet hooks by Act 4/2009 with effect from 1.4.1999 which itself would demonstrate that Entry 1A is illustrative and not exhaustive. He would also submit that the word used in the entry ‘namely’ would itself suggest that the items does not restrict itself to the one’s that are mentioned in the entry but it would also take within its sweep other entries which would fall under the heading-Tailoring Materials. In support of his submission, he relies upon the following judgments: i) VEE NISSAN ELECTRONICS –vs- COMMISSIONER OF CENTRAL EXCISE, MIMBAI [2004(164) E.L.T.3] ii) MAHINDRA ENGINEERING AND CHEMICAL PRODUCTS LTD. – vs- UNION OF INDIA[ 1992(1) SCC 727 ] iii) GREAT EASTERN IMPEX PRIVATE LIMITED –vs- STATE OF KARNATAKA [2008 (64) KLJ 7] 6. Per contra, Smt. Sujatha, learned Additional Government Advocate appearing for the respondent/assessee would support the order passed by the authorities and contend that while interpreting a entry in a taxing statutes it is to be read with reference to the entries specifically provided for in the entry itself and expanded meaning should not be given un less the intention of the Legislature is so found in the entry itself. She would submit that Entry 1-A is exhaustive and it cannot be held to mean or to import into it the other materials which the assessee now claims to be brought within the sweep of tailoring materials. She would submit the word ‘namely’ is to be read as exhaustive and once such exhaustive interpretation is extended to the entry in question, it is only the items that have been mentioned in the entry which alone would be qualified for being brought within such entry and if there are any other materials which have been consciously omitted by the Legislature, it would fall under the residuary entry and as such Assessing Officer as well as the Appellate Authorities are justified in rejecting the contention of the assessee. In support of her submission, she relied upon the following judgments. i) MAHARASHTRA HYBRID SEEDS COMPANY LIMITED –vs-STATE OF KARNATAKA [ 1999 STC 119 ] ii) BALAJI COMPUTERS AND OTHERS –vs- STATE OF KARNATAKA AND OTHERS [ILR 2006 KAR. 38] 7. In support of her submission, she relied upon the following judgments. i) MAHARASHTRA HYBRID SEEDS COMPANY LIMITED –vs-STATE OF KARNATAKA [ 1999 STC 119 ] ii) BALAJI COMPUTERS AND OTHERS –vs- STATE OF KARNATAKA AND OTHERS [ILR 2006 KAR. 38] 7. Having heard the learned advocates appearing for the parties, it would be of benefit to extract the relevant entry which has been pressed into service by the learned advocates appearing for the parties as also the residuary entry under which the revenue claims to charge the assessee for being taxed viz,, Section 5(1) and Schedule II (T) Entry-1- “5. Levy of tax on sale or purchase of goods.--- (1) Every dealer shall pay for each year tax on his taxable turnover at the rate of twelve per cent at the point of first sale. Provided further that if and to the extent to which such turnover, relates to cast iron castings, all the provisions of this Act including the rate of tax applicable to goods mentioned in sub-item (i) of item (a) of Entry 2 of Fourth Schedule shall apply mutatis mutandis, in respect of tax payable under this Act for sale of cast iron castings. Provided further that if and to the extent to which such turnover relates to cast iron casting all the provisions of this Act including the rate of tax applicable to goods mentioned in sub-item (i) of item (a) of Entry 2 of Fourth Schedule shall apply mutatis mutandis in respect of tax payable under this Act for sale of cast iron castings. Provided also that if and to the extent to which such turnover relates to fried gram, all the provisions of this Act including the rate of tax applicable to pulses mentioned in Serial Number 10 of the Fourth Schedule shall apply mutatis mutandis. In respect of tax payable under this Act for sale of fried gram. Provided also that if and to the extent to which such turnover relates to fried gram, all the provisions of this Act including the rate of tax applicable to pulses mentioned in Serial Number 10 of Fourth Schedule shall apply mutatis mutandis in respect of tax payable under this Act for sale of fried gram.” Schedule II PART-T Entry-I-A: 8. Provided also that if and to the extent to which such turnover relates to fried gram, all the provisions of this Act including the rate of tax applicable to pulses mentioned in Serial Number 10 of Fourth Schedule shall apply mutatis mutandis in respect of tax payable under this Act for sale of fried gram.” Schedule II PART-T Entry-I-A: 8. Before delving upon the issues or the points canvassed by the learned counsel for the assessee and the revenue, it would be of necessity to extract the judgment of the Hon’ble Supreme Court in the case of COMMISSIONER OF INCOME TAX, BOMBAY – vs- MANUFACTURING COMPANY LTD [ AIR 1992 SC 1782 ] whereunder the interpretation of taxing statutes and the textual meaning in which it has to be read has been explained by their Lordships and same reads as under: “9. Logic alone will not be determinative of a controversy arising from a taxing statute. Equally, common sense is stranger and incompatible partner to the Income-tax Act. It is not concerned itself with the principles of morality or ethics. It is concerned with the very limited questions as to whether the amount brought to tax constitutes the Income of the assessee. It is equally settled law that if the languages is plain and unambiguous one can only look fairly at the language used and interpret it to give effect to the legislative animation. Nevertheless tax laws have to be interpreted reasonably and in consonance with justice adopting purposive approach. The contextual meaning has to be ascertained and given effect to. A provision for deduction, exemption or relief should be construed reasonably and in favour of the assessee. The object being that in computation of the net income, the statute provides deductions, exemptions or depreciation of the value of the capital assets from taxable income. Therefore, buildings which have not been specifically defined to include road in the Act must be taken in the legal sense.”(Emphasis Supplied by us) 9. Keeping the principles enunciated by their Lordships in the above decision, the facts of the present case are being examined. 10. Items or the items, which are being charged under the residuary entry in the instant case are “self adhesive, cotton rolls, wadding rolls, brass pins and P.M.Pins”. It is the contention of Mr. Keeping the principles enunciated by their Lordships in the above decision, the facts of the present case are being examined. 10. Items or the items, which are being charged under the residuary entry in the instant case are “self adhesive, cotton rolls, wadding rolls, brass pins and P.M.Pins”. It is the contention of Mr. Surya Kanth that these items are traceable to Entry 1-A of Part-T of Schedule II of the Act namely as Tailoring Materials. Under entry 1A Tailoring Materials have been defined as extracted herein above. 11. In view of the word ‘namely’ having been used in the said entry it has been pressed into service by the assessee to contend that goods mentioned therein are to be construed as illustrative and not exhaustive. He has also contended that in view of the Legislatures itself having added certain items by amending Act No.4/1999 with effect from 1.4.1999, it would go to show entry is illustrative and hence new goods were included in the entry and a such the assessee claims that items in question would fall under the heading ‘tailoring materials’. It would be of necessary to examine the word ‘namely’ as has been interpreted by this Court in the case of BALAJI COMPUTERS whereunder at para-92, the different definitions from various dictionaries came to be analysed and it was observed as under: “Section 6-B of the Act provides for levy of resale tax on every registered dealer and every dealer who is liable to get himself registered under sub-sections (1) and (2) of Section 10. Sl.No.20(i) refers to various types of computers in respect of which tax is leviable. After the words ‘Computer of all kinds’ the word ‘namely’ is used, setting out the various types of computers like mainframe, mini, personal, micro computers and the like. The words ‘and the like’ is indicative of the fact that various types of computers similar to mainframe, mini, personal and micro-computers. There cannot be any dispute on this position. Immediately after the description of various types of computers, the words ‘and the like’ and the words ‘and their parts’ are referred to. The question is, the words ‘and their parts’ following the words ‘and the like’ are to be read conjunctively as contended by the learned Counsel for the assesses, or distinctively as contended by the learned Advocate General and they should be excluded from the definition of Computer? The question is, the words ‘and their parts’ following the words ‘and the like’ are to be read conjunctively as contended by the learned Counsel for the assesses, or distinctively as contended by the learned Advocate General and they should be excluded from the definition of Computer? In my view, it is not possible to read the words ‘and their parts’ distinctively as it follows the words ‘and the like’. It is necessary to point out that the items mentioned in Sl.No.20 are made liable for sales tax under Section 5(3) of the Act. Under these circumstances, if the legislature intended to notify various types of computers specifically referred to in Sl.No.20 of Part ‘C’ of second schedule of the Act, and also the types of computers which are similar to the various types of computers referred to in Sl.No. 20(i) of Part ‘C’ of second schedule and in addition to that if the legislature intended that its parts also should be read as computer. It is reasonable to take the view, by legal fiction, the legislature, for the purpose of levy of tax under the Act, wanted parts of computer also to be treated as computers. It cannot be denied, computer is produced by assembling various parts or configuration. Therefore, for the purpose of levy of tax, if the legislature, by means of legal fiction or definition, intended to treat the parts of computers as computers, we do not find anything wrong in that. In the context the words, ‘and their parts’ occurring immediately after specific reference to ‘main frame, mini, personal, micro-computers and the like’ should be understood that the parts of computes are also treated as computers by legislative intendment. In Webster’s Encyclopaedic Unabridged Dictionary of the English Language, the word ‘namely’ has been stated as ‘that is to say, explicitly, specifically to wit an item of legislation, namely certain bill. In World Book Dictionary, the word ‘namely’ has been stated as ‘that is to say, to wit’. Therefore, the word ‘namely’ ordinarily imports of what is comprised in the proceeding clause; and it ordinarily serves of equating what follows with the clause described before. In World Book Dictionary, the word ‘namely’ has been stated as ‘that is to say, to wit’. Therefore, the word ‘namely’ ordinarily imports of what is comprised in the proceeding clause; and it ordinarily serves of equating what follows with the clause described before. In the case of BHOLA PRASAD vs EMPEROR referred to by the Supreme Court in the case of BOMBAY EDUCATION SOCIETY (SUPRA), the words ‘that is to say’ have been described as ‘explanatory or illustrative words and not words either of amplification or limitation.’ In the case of BOMBAY EDUCATION SOCIETY (SUPRA), THE Supreme Court while considering what is the meaning that is required to be given to the word ‘namely’ employed in the circular issued by the State of Bombay directing that no primary or secondary School shall, from the date of the order, admit to a class where English is used as a medium of instruction any pupil other than a pupil belonging to a section of citizens the language of which is English wherein it is explained by stating ‘namely’ Anglo-Indians and citizens of non-Asiatic descent, has observed that ordinarily the word ‘namely’ imports enumeration of what is comprised in the proceeding clause and it ordinarily serves the purpose of equating what follows with the clause described before. Further, the word ‘namely’ has also been explained in the said decision and also in the Oxford English Dictionary as ‘that is to say’. In this connection, it is useful to refer to the observation made by the Court at paragraph 12 of the judgment which reads as hereunder. “12. Re (1) : As already indicated Barnes High School is a recognized Anglo-Indian School which has all along been imparting education through the medium of English. It receives aid out of State funds. The daughter of Major Pinto and the son of Dr.Gujar are citizens of India and they claim admission to Barnes High School in exercise of the fundamental right said to have been guaranteed to them by Article 29(2) of the Constitution. The School has declined to admit either of them in view of the circular order of the State of Bombay. The provisions of the circular order, issued by the State of Bombay on the 6th January 1954, have already been summarized above. The School has declined to admit either of them in view of the circular order of the State of Bombay. The provisions of the circular order, issued by the State of Bombay on the 6th January 1954, have already been summarized above. The operative portion of the Order, set forth in clause 5 thereof, clearly forbids all Primary or Secondary Schools, where English is used as a medium of instruction, to admit to any class any pupil other than a pupil belonging to a section of citizens, the language of which is English namely Anglo-Indians and citizens of non-Asiatic descent. The learned Attorney General contends that this clause does not limit admission only to Anglo-Indians and citizens of non-Asiatic descent, but permits admission of pupils belonging to any other section of citizens the language of which is English. He points out that one of the meaning of the word “namely” as given in oxford English Dictionary volume VIII p.16 is ‘that is to say’ and he then refers us to the decision of the Federal Court in –‘Bhola Prasad vs Emperor’, AIR 1942 FC 17 at p.20 (A). where it was stated that the words ‘that is to say’ were explanatory or illustrative words and not words either of amplification or limitation. It should, however, be remembered that those observations were made in connection with one of the Legislature heads, namely entry No.31 of the Provincial Legislative List. The fundamental proposition enunciated in – “The Queen vs Burah.” (1878) 3 AC 889 (B) was that Indian Legislatures within their own sphere had plenary powers of legislation as large and of same nature as those of Parliament itself. In that view of the matter every entry in the legislative but had to be given the widest connotation and it was in that context that the words “that is to say’, relied upon by the learned Attorney – General, were interpreted in that way by the Federal Court. To do otherwise would have been to cut down the generality of the legislative head itself. The same reason cannot apply to the construction of the Government Order in the present case for the considerations that applied in the case before the Federal Court have no application here. Ordinarily the word ‘namely’ imports enumeration of what is comprised in the preceding clause. The same reason cannot apply to the construction of the Government Order in the present case for the considerations that applied in the case before the Federal Court have no application here. Ordinarily the word ‘namely’ imports enumeration of what is comprised in the preceding clause. In other words it ordinarily serves the purpose of equating what follows with the clause described before. There is good deal of force, therefore, in the argument that the order restricts admission only to Anglo-Indians and citizens of non-Asiatic descent whose language in English. This interpretation finds support from the decision mentioned in clause 4 to withdraw all special and interim concessions in respect of admission to Schools referred to in clause 4. Facilities to linguistic minorities provided for in the circular order, therefore, may be red as contemplating facilities to be given only to the Anglo-Indians and citizens of non-Asiatic descent.” (emphasis supplied) 12. In yet another judgment this Court in the case of MAHARASHTRA HYBRID SEEDS COMPANY LIMITED the word ‘namely’ used in Entry 16-A (v) of the Act was the subject matter of consideration which came to be analysed and held as under: “11. Normally speaking, the courts while giving a meaning to an item contained in the Schedule give it the meaning which the makers of the Schedule intended by grouping various articles in a particular group considering them in a generic sense. On a reading of entry 16-A and its analysis, it is evident that the legislature did not intend to tax all packing materials. Intention is to tax certain items made out of specified materials enumerated in clauses (i) to (vi). By putting the word “namely” after the words “packing material” in the heading of entry 16-A, the Legislature intends to specify the packing materials made out of a particulars commodity to be taxed under the Act. Clause (i) deals with packing materials made out of paper, (ii) with tin and other metals, (iii) from plastic, (iv) with wood,, (v) from jute fibre and (vi) with glass. 12. In this case, we are concerned with the packing materials made out of jute and not any other material. Under clause (v) the packing materials made out of jute have been brought to tax. There are three items in entry (v); (a) gunny bags, (b) bardan (including batars) and (c) Hessian cloth. 12. In this case, we are concerned with the packing materials made out of jute and not any other material. Under clause (v) the packing materials made out of jute have been brought to tax. There are three items in entry (v); (a) gunny bags, (b) bardan (including batars) and (c) Hessian cloth. Counsel for the parties are agreed that gunny bags and bardans (including batars) is made out of jute. “Hessian” as per Shorter Oxford Dictionary means “strong coarse cloth of hemp or jute; sack-cloth”. In the same dictionary “hemp” means “plant from which coarse fibres are obtained for the for the manufacture of rope and cloth”. Thus all the three entries in clause (v) relate to fibre made out of jute. After these entries, the Legislature has added the words “and the like” have been added at the end of entries. The words “and the like” will have to go with the description of the items in the clause and would not include an item which is not conceived in the entry. In clause “(v), the intention is to subject to tax the packing materials made out of jute only and not out of any other material like cloth, polythene, etc. June is the basic fibre and the packing materials made out of jute only are subjected to tax. The expression “and the like” would require to be considered “ejusdem generls”. The genesis or the class of items envisaged by the preceding words not being exhaustive of the genesis or the class, the Legislature has conceived the words “and the like” so as to bring in any other item of the same class or genesis. In entry 16-A, broadly speaking the packing materials of different meals and materials have been mentioned and the reference to the words “and the like” will have to go separately with the description in each item and would not go beyond that to any other item not conceived in such each sub item. The reference in entry 16-A(v) is with reference to gunny bags, bardan (including bataras), Hessian cloth and the words “and the like” extending the principle of ejusdem generic would not conceive cotton cloth bags within that group to subject the petitioner to entry tax.” (Emphasis Supplied by us) 13. Mr. Surya Kanth, has referred to MAHINDRA ENGINEERING (supra) wherein it has been held at paragraph-3 to the following effect: “3. Mr. Surya Kanth, has referred to MAHINDRA ENGINEERING (supra) wherein it has been held at paragraph-3 to the following effect: “3. The entry is in two parts, one, descriptive and the other explanatory. Both are to be read together to bring out the scope and extent of its applicability fully. The first declares the items, which are exigible to duty. But restricts it to only those in relation to the manufacture of which any process is ordinarily carried on with the aid of power. Having thus specified the items and the condition on which it would be covered in the entry it proceeds to amplify it in the second part by using the words ‘following namely’ thus explaining the items that were intended to be covered in this entry. Use of expressions ‘namely’, or ‘that is to say’ followed by description of goods is usually exhaustive unless there are strong indications to the contrary. Language of serial No.4 is plain and simple. It intends to clarify the expression ‘manufacture therefrom’ by expanding it to include in its ambit even those manufactures in which fibre or yarn predominated in weight. But it did not go beyond it and purported to include manufactures out of manufacture of a commodity in which mineral fibre or yarn predominated. The entry was added in 1980. That give an occasion for the learned counsel for Union of India to urge that it was intended to evade payment of duty by widening and expanding the ambit of entry. In our opinion the item cannot be construed in the manner suggested. The entry was widened but to the extent indicated above. Any other construction would result in altering the principal clause. That would be contrary to the scheme of the entry and principle of construction. Its only effect was to include even those manufactures in which mineral fibre or yarn or both predominate. It could not be extended to those goods which were manufactured out of certain commodity in which mineral fibre or yarn had been predominantly used. The word ‘other manufacture’ has to be read in the same sense a ‘manufacture therefrom’ used in the main part. The only difference is that the scope has been widened to include not only those goods which were manufactured from mineral or yarn but even to those in which they predominate. The word ‘other manufacture’ has to be read in the same sense a ‘manufacture therefrom’ used in the main part. The only difference is that the scope has been widened to include not only those goods which were manufactured from mineral or yarn but even to those in which they predominate. The construction as suggested by the learned counsel for Union of India shall not only change the nature of entry but it shall result in extending to manufactures at any stage. In Geep Flashlight Industries v. Union of India’ the entry to mean an article made wholly of commodity commonly known as plastic to avoid any artificial reading. The word ‘wholly’ was read in the entry to render it workable. Thus glass fabric manufactured out of mineral fibre is exigible to duty under Item 4 but are chamber housing manufactured from glass fabric cannot be placed at par with glass fabric and cannot be considered as ‘other manufacture’ of glass fibre or yarn.” 14. The words used in a fiscal statue has to be read as exhaustive until and unless the Legislature intends otherwise by using the words such as “and the like” or etc., and only in such circumstances, the principles of ejusdem generis may be applicable and not otherwise. It would be the responsibility of the Courts to embark upon an enquiry to find out as to whether such commodity would form either part of genises or species and not in a circumstances of this nature. The word “namely” that has been used in the present entry in unequivocal terms indicate that it is exhaustive and is referable to only those entries specifically mentioned in Entry 1-A particularly in the absence of the words ‘and the like’ or ‘etc’. The word “namely” used in Entry IA of Part-II, Schedule II is preceeding the description as a “prefix”. It is not used as a “suffix” like use of words “and the like”, “etc” at the end of entries/commodities so as to bring within its sweep other commodities of like nature. In the absence of same “ejusdem generis” interpretation cannot be adopted and entry has to be held exhaustive. 15. It is not used as a “suffix” like use of words “and the like”, “etc” at the end of entries/commodities so as to bring within its sweep other commodities of like nature. In the absence of same “ejusdem generis” interpretation cannot be adopted and entry has to be held exhaustive. 15. The judgment of MAHINDRA ENGINEERING pressed into service by the learned Counsel for the assessee was a matter arising under the Central Excises and Salt Act, 1944 whereunder the “tubular shaped chamber housings” manufactured by the assessee by using glass fibre was the subject matter of consideration. The relevant entry under CETA read as under:“33-F. Mineral fibres and yarn and manufactures therefrom, in or in relation to the manufacture of which any process is ordinarily carried on with the aid of power, the following, namely; (1) glass fibres and yarn including glass tissues and glass wool; (2) asbestos fibre and yarn; (3) any other mineral fibre of yarn, whether continuous or otherwise, such as slag wool and rock wool; (4) other manufactures in which mineral fibres or yarn or both predominate or predominates in weight. Explanation: This item does not include asbestos cement products.” The words used in said entry was with reference to the “manufacture” either by any process ordinarily carried or with the aid of the power and these words were qualified with the word ‘namely’. It is in this background, their Lordships have interpreted the word ‘namely’ and concluded that use of expression ‘namely’ as suffix after the description of goods is usually illustrative unless there are strong indications to the contrary. We do not find in the instant such strong indications to take a stand or a view to hold that entry is not exhaustive or to hold that entry in question is illustrative. Merely because the Legislature has thought fit in its wisdom to bring additional goods under Entry 1A of Part T, Schedule II ipso-facto would not lead to a conclusion that entry has to be illustrative. While interpreting a fiscal statute general principle to be adopted is to examine the entry as on the date relevant to the assessment year. As such we are unable to accept the argument advanced by the learned Counsel for the appellant. Hence the judgment of MAHINDRA ENGINEERING referred to supra would not be applicable to the facts of the present case. 16. As such we are unable to accept the argument advanced by the learned Counsel for the appellant. Hence the judgment of MAHINDRA ENGINEERING referred to supra would not be applicable to the facts of the present case. 16. In so far as VEE NISSAN case referred to by the learned Counsel for the assessee, we find in the said case that ‘Rack Series System’ manufactured by the assessee therein was brought under residuary clause as against the contention of the assessee to bring it within the Tariff Item No.33F under the heading “Musical Systems”. The admitted facts in the said case was that “Rack Series System” manufactured by the assessee included “amplifier, graphic equalizer, speakers, cassette deck and turntable”. In this background their Lordships came to a conclusion that these items viz., cassette deck, amplifier, etc., could not be held that it is not a musical system and as such it was held that it cannot fall under residuary clause and it ought to fall under the heading “Musical Systems’ Entry 33F of CETA. Hence, said judgment is also not applicable to the facts of the case. 17. In the instant case, we find that goods ‘self adhesive tapes, cotton rolls, wadding rolls, brass pins or P.M.Pins’ cannot be said to form part of tailoring items to fall either under the genesis or species. Hence, it is held and concluded that these items cannot be held to form part either genesis or they are under the species of genesis coming under the category of “tailoring items”. 18. In view of the above discussion, we are of the considered view that question of law formulated herein above requires to be answered against the assessee and in favour of the revenue and consequently, revision petition is dismissed. No orders as to costs.