Taxing notification hierarchy preserves specific rate for motor vehicle batteries where later notification does not cover component parts.

Batteries used in motor vehicles remained taxable at the earlier specific rate for motor vehicles and their component parts, including batteries, because the later notification under section 3-A of the U.P. Sales Tax Act covered only scheduled goods and did not address motor vehicles or their component parts. A later taxing notification supersedes an earlier one only to the extent of actual inconsistency or repugnancy, and no such conflict arose here. The specific rate of six pies per rupee therefore continued to apply to motor vehicle batteries, and the assessee succeeded.

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Issues: Whether batteries used in motor vehicles were taxable at the rate of six pies per rupee under the earlier notification, or at seven per cent as "electrical goods" under the later notification.

Analysis: The earlier notification specifically dealt with motor vehicles and their component parts, including batteries, and prescribed the rate of six pies per rupee. The later notification under section 3-A of the U.P. Sales Tax Act prescribed a rate for goods included in its schedule, but did not make any provision for motor vehicles or their component parts. A later notification supersedes an earlier one only to the extent of inconsistency or repugnancy. Since the later notification did not cover motor vehicles or their component parts, it could not displace the earlier specific rate applicable to batteries as component parts of motor vehicles.

Conclusion: Batteries used in motor vehicles were taxable at six pies per rupee under the earlier notification, and the assessee succeeded on the reference.

Ratio Decidendi: A later taxing notification overrides an earlier specific notification only to the extent of actual inconsistency or repugnancy, and a specific rate for component parts remains applicable where the later notification does not cover that subject.

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