Classification of leather washers and belts as machinery parts failed for lack of material supporting the claim.

Washers and leather belts were not shown, on the material before the HC, to be only spare parts or component parts of machinery, despite being made of leather. The Court held that their classification depended on the meaning of "machinery" and on a factual determination of whether the articles were machinery parts or fell within the relevant leather goods entry. Because the assessee produced no material to support that characterisation, the Court declined to undertake the necessary factual inquiry and left the first two referred questions unanswered.

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Issues: Whether, on the material placed before the Court, the first two referred questions concerning washers and leather belts could be answered as articles falling within the relevant sales-tax entry for leather goods or as component parts of machinery.

Analysis: The Court noted that the character of the articles had to be determined with reference to the meaning of "machinery" and to whether the articles were spare parts or component parts of machinery. It held that the assessee had produced no material to show that the washers and leather belts, though made of leather, could only be regarded as machinery parts. In the absence of such material, the Court declined to undertake the factual determination necessary to answer the first two referred questions.

Conclusion: The first two referred questions were not answered.

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