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Issues: Whether chromo-steel back wrist watch-cases are "spare parts" of watches within entry 10 of Schedule E to the Bombay Sales Tax Act, 1959, or fall under the residuary entry 22.
Analysis: Entries in sales tax legislation are to be construed in their common or popular sense, as understood in ordinary commercial parlance. A wrist watch, in that sense, comprises not merely the mechanism but the mechanism fitted into the watch-case, and the case is an integral constituent of the commercial article. A spare part is an integral part kept in reserve for substitution or replacement, and the watch-case satisfies that description because it is severable and replaceable. For a wrist watch, the case is also essential to its use as a wrist watch.
Conclusion: The watch-cases are spare parts of watches and are covered by entry 10 of Schedule E; they do not fall in the residuary entry 22.
Ratio Decidendi: In sales tax entries, goods are classified according to their common parlance meaning, and an integral, severable, and replaceable constituent of a commercial article may be treated as a spare part where it is essential to the article as sold and used.