Finished leather seat covers are a distinct commodity and taxable as leather goods, not cycle parts or accessories.

A leather seat cover made from thick tanned leather is a finished article distinct from tanned leather itself for sales tax purposes. Its character is determined by the commodity as sold and used, not by the possibility of flattening it back into leather. The covers are also not cycle parts or accessories, because a cycle seat comes into existence only when the cover is fitted with other components, and the notification concerns accessories of the vehicle rather than of a part of it. They fall within the leather goods entry, which covers articles made of leather other than footwear, and are taxable accordingly.

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Issues: (i) Whether cycle seat covers made of thick tanned leather constitute a commodity different from tanned leather. (ii) Whether such leather seat covers are taxable as leather goods or as cycle parts or accessories under the relevant sales tax notifications.

Issue (i): Whether cycle seat covers made of thick tanned leather constitute a commodity different from tanned leather.

Analysis: A seat cover made of tanned leather is a finished article distinct from the raw or base commodity of tanned leather. The fact that the cover may be flattened back into leather does not make it the same commodity for sales tax purposes. The legal character of the article is determined by what it is as sold and used, not by the material from which it is made.

Conclusion: The seat covers are a commodity different from tanned leather, and this issue is answered in favour of the Revenue and against the assessee.

Issue (ii): Whether such leather seat covers are taxable as leather goods or as cycle parts or accessories under the relevant sales tax notifications.

Analysis: The covers are not cycle parts because a cycle seat comes into existence only after the leather cover is mounted with springs, nuts, and bolts, and the component parts taken separately are not cycle parts. They are also not accessories of the cycle as a whole, since the notification contemplates accessories of the vehicle and not accessories of a part of the vehicle. On the other hand, the notification describing leather goods is comprehensive and includes articles made of leather other than footwear. The leather seat covers squarely fall within that description.

Conclusion: The leather seat covers are taxable as leather goods under the notification for leather goods and not as cycle parts or accessories under the cycle parts notification.

Final Conclusion: The reference was answered against the assessee, with the leather seat covers held to be a distinct commodity and taxable under the leather goods entry.

Ratio Decidendi: A finished article made of leather is a distinct taxable commodity from the leather material itself, and an article used only in the fabrication of a vehicle part is not necessarily a part or accessory of the vehicle for sales tax classification.

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