High Court held that  assessee, was  engaged in contract carriage of goods, lifted goods for delivery but did not deliver them, addition of value of goods short delivered in hands of assessee was justified. On appeal, allowing the appeals the Court held that for the purposes of section 69A of the Act, the deeming effect of the provision will only apply, firstly, if the assessee is the owner of the goods and secondly, for any article to be considered a “valuable article” under section 69A, it must be intrinsically costly, and it will not be regarded as valuable if a huge mass of a non-precious and common place article is taken into account, for imputing high value. Bitumen was not a valuable article in the context of section 69A and the assessee was not the owner of the bitumen for the purpose of section 69A of the Act. The assessee was engaged as a carrier to deliver the bitumen, after having lifted it from the oil companies, to the various Divisions of the Road Construction Department of the Government of Bihar. It was not the case of either party that the assessee had become the owner of the bitumen in question in a manner authorised by law. On the other hand, the specific case of the assessee was that the assessee never became the owner and it remained only a carrier. However, there had been short delivery, which would mean that the assessee continued in possession contrary to the terms of contract of carriage. Possession of the goods was clearly wrongful when it continued with the assessee contrary to the terms of the contract and the law. The assessee did not possess the power of alienation. The assessee could at no point of time have claimed rights over the bitumen as an owner. The possession of the assessee had its origin under a contract of bailment. The assessee was bereft of any of the rights or powers associated with ownership of property and the Assessing Officer acted illegally in holding that the assessee was the owner.  Thus, bitumenas such could not be treated as a valuable article.  The assessee was certainly not the owner of the bitumen. Due to short delivery of goods, the possession of the assessee was unlawful. The inevitable conclusion therefore was that the assessee was not the owner, for the purposes of section 69A. Articles of value are a genus of which valuable articles are a species, i. e., a subset of high priced items. To put it differently, an article having value, may not be a valuable article. To categorise all sundry items as valuable articles will be an interpretation foreign to the purpose of the law and the intention of the Legislature in so far as section 69A is concerned. Circular No. 20 of 1964 dated July 7, 1964 stated that the 1964 amendment was enacted not to subject lower middle-class people to taxation by taxing gold or jewellery inherited from forefathers, but was mandated for “big assessees” who convert their black money and unaccounted wealth into gold jewellery and gold vessels and claim these to be heirlooms. The Legislature never intended that any and every article of value should be brought within the ambit of section 69A. The intent of the Legislature through the amendment was to subject articles like gold, jewellery and other valuable items, to Income-tax, where such articles are typically owned with the intention of avoiding Income-tax.  When the principle of ejusdem generis is applied, the preceding words in section 69A, money, bullion, jewellery would suggest that the phrase “other valuable article” which follows those words, would justify inclusion of only high value goods. Any other way of reading the phrase “other valuable article” or “valuable article” by ignoring the kind of specific goods mentioned in the preceding part of section 69A, would be incorrect and would do violence to the plain language of the provision and travel beyond the legislative intent. Additionally, the maxim “noscitur a sociis” (i. e., a word is known by its associates) would also support this view that the other valuable articles should be items in the nature of silver bars, or jewellery or money, i.e., only high-priced item. To include bitumen, the residual offshoot material during processing of crude oil, excluding its valuable constituents like petrol, diesel, LPG, aviation fuel, etc., within the expression “other valuable article” in section 69A, would result in absurdities, and was to be eschewed.  The principle that a fiscal statute should be strictly construed is well settled. For purposes of interpreting section 69A of the Act the ordinary and literal meaning should be adopted as the words in the statute are clear and unambiguous.  The phrase “valuable article” would simply mean an item “worth a great deal of money”. It cannot include “any article of value”. An ordinary “article” cannot be bracketed in the same category as other high-priced articles like bullion, gold, jewellery mentioned in section 69A by attributing high value to it only on the strength of its bulk quantity.(AY. 1995-96, 1996-97)