Commercial identity governs sales tax classification of typewriter ribbons, which are not treated as parts of typewriters.

Typewriter ribbons were held not to be parts of typewriters for sales tax classification under entry 18 of the Mysore Sales Tax Act, 1957. The decisive test was commercial identity and market understanding, not the fact that a typewriter cannot function without a ribbon. Because ribbons were not ordinarily manufactured or supplied as spare parts by typewriter manufacturers and were sold separately in the market, they lacked the character of an essential machine part. They were therefore assessable under section 5(1) rather than within the specific entry for typewriter parts.

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Issues: Whether typewriter ribbons are to be classified as parts of typewriters under entry 18 of the Second Schedule to the Mysore Sales Tax Act, 1957, or taxed under section 5(1) of that Act.

Analysis: Classification of an article for sales tax purposes depends on its commercial understanding and market treatment. A mere inability of a machine to function without an accessory does not, by itself, make that accessory a part of the machine. The record showed that typewriter ribbons were not ordinarily manufactured or supplied by typewriter manufacturers as spare parts, and they were sold in the market separately from typewriters. On that basis, typewriter ribbons could not be treated as an essential part of a typewriter for the purpose of entry 18.

Conclusion: Typewriter ribbons do not fall under entry 18 of the Second Schedule to the Mysore Sales Tax Act, 1957, and are liable to be assessed under section 5(1) of the Act.

Ratio Decidendi: For sales tax classification, an accessory is not a part of a machine merely because the machine cannot operate without it; the decisive test is commercial identity and market understanding.

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