Common parlance test for machinery: sugarcane crusher qualifies as machinery despite animal power.

A sugarcane crusher was treated as machinery for sales tax classification under Entry No. 60 because the term was not defined in the statute and had to be understood in its common parlance sense. A mechanical contrivance with interrelated parts that applies force to achieve a definite result remains machinery regardless of whether it is powered by animals, humans, or electricity. The crusher's rollers and working arrangement were held to constitute machinery for crushing sugarcane and extracting juice, and the turnover was therefore liable to tax under the relevant entry.

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Issues: Whether a sugarcane crusher or sugarcane crushing mill is machinery within Entry No. 60 of the taxable list under the Orissa Sales Tax Act, 1947.

Analysis: The expression "machinery" was not defined in the statute and had therefore to be understood in its common parlance sense. The accepted approach was that machinery means a mechanical contrivance by which force is applied through interrelated parts to achieve a definite result, and the source of power does not change its character. On that basis, the fact that the crusher operated through animal power rather than electric or mechanical power did not exclude it from the concept of machinery, because the rollers and their working arrangement constituted a contrivance for crushing sugarcane and extracting juice.

Conclusion: A sugarcane crusher or sugarcane crushing mill is machinery and falls within Entry No. 60.

Final Conclusion: The reference was answered in the affirmative, and the disputed turnover was held liable to tax as machinery under the relevant entry.

Ratio Decidendi: For tax classification in common parlance, a device remains machinery if it is a mechanical contrivance with interdependent parts that applies force to perform a specific function, regardless of whether the power source is human, animal, or mechanical.

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