Classification of leather beltings and washers depends on commercial meaning; they remain leather goods, not mill stores.

Leather beltings and leather washers were considered under Notification No. ST-747/X-950 (22)-67 by applying their commercial meaning and the scope of the entries for mill stores and hardware. Mill stores were treated as small tools and spare parts of machinery, while hardware referred to small base-metal items. Leather beltings were not regarded as tools, spare parts, or component parts of machinery in that sense, and leather washers, though used in machinery, also did not fit those descriptions. Both items therefore retained their character as leather goods and were not taxable as mill stores under the notification, attracting the lower rate applicable to leather goods.

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Issues: Whether leather beltings and leather washers were taxable as mill stores under Notification No. ST-747/X-950 (22)-67 dated 1 March 1968, or whether they fell within leather goods.

Analysis: The classification turned on the commercial understanding of the relevant entries in the notification. Mill stores were understood to comprise small tools and spare parts of machinery, while hardware covered small base-metal items. Leather beltings, following earlier decisions on similar beltings, were held not to be tools, spare parts, or component parts of machinery in the relevant sense. Leather washers, though used in machinery, were also found not to answer the description of small tools or spare parts, and they did not fall within hardware either. On that construction, both items retained the character of leather goods rather than mill stores.

Conclusion: Leather beltings and leather washers were not taxable as mill stores under the notification and were correctly treated as leather goods liable to the lower rate of tax.

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