Accessory goods used with chaff-cutters can qualify for exemption when they support efficient operation as subordinate accompaniments.

Oil-cans and steel files sold only with chaff-cutters were treated as accessories rather than independent unclassified goods because they accompanied the main article and contributed to its efficient working in a subordinate way. The term "accessory" was applied in its ordinary sense, and the composite billing for the unit supported their connected character. On that basis, the earlier exemption notification for agricultural implements and their accessories was held applicable, while the later notification relied on by the revising authority was found inapposite. The turnover of the oil-cans and steel files was therefore treated as exempt from tax.

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Issues: Whether oil-cans and steel files sold along with chaff-cutters were accessories of chaff-cutters and, therefore, exempt from tax under the relevant exemption notification, or were taxable as unclassified goods.

Analysis: The articles were sold only with chaff-cutters and were covered by a composite bill for the entire unit. Oil-cans were used for oiling and lubricating the chaff-cutter, while steel files were used for sharpening its blades. The term "accessory" was not defined in the Act, and in its ordinary sense it denoted something that accompanied and contributed in a subordinate degree to the main article. On that basis, the articles were treated as accompaniments of the chaff-cutter and as contributing to its efficient working. The later notification relied on by the revising authority was found not to be the appropriate one, and the earlier notification exempting agricultural implements and their accessories was held applicable.

Conclusion: Oil-cans and steel files were accessories of chaff-cutters and their turnover was exempt from tax.

Ratio Decidendi: Articles sold with and used for the efficient operation of an exempted main article may be treated as its accessories where they are subordinate accompaniments rather than independent goods.

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