Cotton belts treated as cotton fabric for exemption, despite possible classification as parts or accessories.

Cotton belts made of cotton and used for transmission of power or rotation were treated as cotton fabric because anything fabricated out of cotton can fall within that description. On that basis, the goods were eligible for exemption under item 4 of the Third Schedule. The possibility that the same goods could also be classified as parts or accessories under item 81 of the First Schedule did not displace the exemption, as the overlapping classification did not defeat the specific treatment as cotton fabric.

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Issues: Whether cotton belts used for transmission of power or rotation could be treated as cotton fabric falling under item 4 of the Third Schedule, so as to obtain exemption from tax notwithstanding their possible classification as parts or accessories under item 81 of the First Schedule.

Analysis: The goods were cotton belts made of cotton and used for transmitting power or rotation. The Court held that anything fabricated out of cotton can be regarded as cotton fabric. On that basis, the goods answered the description in item 4 of the Third Schedule and were eligible for exemption, even though they might also fall within the description of parts or accessories under item 81 of the First Schedule.

Conclusion: The goods were treated as cotton fabric entitled to exemption, and the contention that classification as parts or accessories displaced that exemption was rejected.

Ratio Decidendi: Goods fabricated out of cotton may be classified as cotton fabric for exemption purposes, notwithstanding a possible overlapping classification as parts or accessories.

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