Ordinary meaning of machinery controls classification of handlooms and related spare parts under sales tax law.

Handlooms were treated as "machinery" under entry 20 of Schedule II of the Mysore Sales Tax Act, 1957, because the term was given its ordinary meaning and did not depend on whether the power source was manual or mechanical. Parts of handlooms therefore fell within that entry. For items described as spare parts, the Court required a fresh factual classification between machine parts and accessories, because each item had to be taxed strictly according to the entry actually applicable. Machine parts were to fall under entry 20, while accessories, if taxable at all, were to be assessed under section 5(1).

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Issues: (i) Whether handlooms are "machinery" for the purpose of entry 20 of Schedule II of the Mysore Sales Tax Act, 1957; (ii) Whether the items sold as spare parts were in fact accessories or machine parts, and how they were to be taxed.

Issue (i): Whether handlooms are "machinery" for the purpose of entry 20 of Schedule II of the Mysore Sales Tax Act, 1957.

Analysis: The expression "machinery" was treated as having no special statutory definition and was therefore given its ordinary and dictionary meaning. A machine was understood as a mechanical contrivance made up of parts operating together to produce a definite result. The mode of power by which it is operated was held not to be decisive, and manual power did not take the article out of the ordinary concept of machinery.

Conclusion: Handlooms are machinery, and parts thereof fall within entry 20 of Schedule II of the Mysore Sales Tax Act, 1957.

Issue (ii): Whether the items sold as spare parts were in fact accessories or machine parts, and how they were to be taxed.

Analysis: The Court accepted that some items described as spare parts might actually be accessories, and that this factual distinction had not been examined by the assessing authority. Since a taxing entry must operate according to the express words used, the classification of each item required fresh examination and could not be assumed against the assessee. The items found to be machine parts would fall under entry 20, while accessories would be taxable, if at all, under section 5(1).

Conclusion: The question of classification required reconsideration by the assessing authority, with machine parts taxed under entry 20 of Schedule II and accessories taxed under section 5(1) of the Mysore Sales Tax Act, 1957.

Final Conclusion: The legal character of handlooms as machinery was affirmed, but the assessment was sent back for fresh classification of the disputed items between machine parts and accessories, with tax consequences to follow that classification.

Ratio Decidendi: In the absence of a statutory definition, "machinery" is to be understood in its ordinary sense, and an article does not cease to be machinery merely because its power is supplied manually rather than mechanically; however, each item must be classified strictly according to the taxing entry actually applicable to it.

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