Electrical goods classification test: a motor-driven lathe retained its character as machinery and escaped the higher sales tax rate.

A lathe fitted with electric motors was held not to be "electrical goods" under section 3(2)(viii) of the Madras General Sales Tax Act. The decisive test was whether the article was essentially an electrical good or only machinery using electricity as its motive power. Applying that principle, the machine retained its essential character as a lathe, since the motors merely supplied power and did not convert it into electrical goods. It was therefore outside the higher sales tax category.

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Issues: Whether a lathe fitted with electric motors constituted "electrical goods" within section 3(2)(viii) of the Madras General Sales Tax Act and was therefore liable to the higher rate of sales tax.

Analysis: The decisive test was whether the machine was essentially an electrical good or merely machinery using electricity as its motive power. The earlier ruling had declined to make an exhaustive list of electrical goods and had indicated that, except where a machine cannot be used without electrical energy, it should ordinarily be treated as non-electrical. Applying that test, the lathe remained a lathe even though it was driven by one main motor and several auxiliary motors. The presence of electric motors supplied power for working the machine, but did not alter its essential character as machinery capable of being adapted to other forms of power.

Conclusion: The lathe did not fall within the category of "electrical goods" and was not liable to the additional rate under section 3(2)(viii).

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