Integrated machinery test extends to screen print tables treated as accessories in manufacturing use.

Where a fiscal entry refers to "machinery" without definition, the expression may extend to an integrated functional assembly of objects working together to produce a specific result, even if the process is largely manual. Screen print block tables fitted with steam pipes for drying and used with mechanical colour-mixing equipment were treated as part of the printing machinery, not as isolated wooden articles. On that reasoning, the tables were regarded as accessories of machinery used in the manufacture of goods and were covered by the relevant schedule entry.

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Issues: Whether screen print block tables sold by the assessee were covered by entry 15 of Schedule C to the Bombay Sales Tax Act, 1959 as machinery used in the manufacture of goods, or its spare parts and accessories.

Analysis: The term "machinery" was not defined in the Act, so its ordinary meaning and the functional character of the printing arrangement had to be considered. A mere manual process does not exclude machinery if the overall arrangement is a complete and integrated collection of objects working in unison to produce a specific result. The tables were fitted with steam pipes for instantaneous drying, colours were mixed mechanically, and the tables formed part of the integrated screen-printing arrangement. The width, length, and use of the tables, together with their connection to the drying and colour-mixing process, showed that they were not isolated wooden articles but part of the machinery employed in printing.

Conclusion: The screen print block tables were accessories of machinery used in the manufacture of goods and were covered by entry 15 of Schedule C. The Tribunal's contrary view was erroneous and the question was answered in favour of the assessee.

Ratio Decidendi: Where a fiscal entry uses the term "machinery" without definition, the expression may include an integrated functional assembly of objects operating together with manual or mechanical force to produce a specific result, and articles forming part of such assembly may be treated as its accessories even if the principal process is substantially manual.

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