D. N. Singh v .CIT (2023)454 ITR 595/ 293 Taxman 550/ 332 CTR 665 / 226 DTR 17 (SC)

Interpretation of Taxing Statutes — Ejusdem Generis — Noscitur A Sociis.

The principle of ejusdem generis applies when the following conditions are present : the statute contains an enumeration of specific words, the subjects of enumeration constitutes a class or category, that class or category is not exhausted by the enumeration, the general terms follow the enumeration, and there is no indication of a different legislative intent. If the subjects of enumeration belong to a broad based genus as also to a narrower genus, there is no principle that the general words should be confined to the narrower genus.

The rule of noscitur a sociis is a rule wider than the rule of ejusdem generis ; rather the latter rule is only an application of the former.