Machinery includes handpump where it functions as a mechanical contrivance for lifting water under the notification.

A handpump was treated as a mechanical contrivance used for lifting water, and devices of that kind had consistently been regarded as machinery where energy is transmitted from one point to another. On that reasoning, the term "machinery" in Notification No. ST-7098/X-1012-1965 dated 1 October 1965 was construed to include a handpump, so the handpump fell within the notification as machinery in favour of the Revenue and against the assessee.

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Issues: Whether a handpump is covered by Notification No. ST-7098/X-1012-1965 dated 1st October, 1965 as "machinery".

Analysis: A handpump was treated as a mechanical contrivance used for lifting water, and such devices had consistently been regarded as machinery where energy is transmitted from one point to another. On that reasoning, the term "machinery" in the notification was held to include a handpump.

Conclusion: The question was answered in the affirmative and the handpump was held to fall within the notification as machinery, in favour of the Revenue and against the assessee.

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