Ordinary meaning of spare parts: windscreen wipers excluded, while an oil gauge was treated as a taxable machinery part.

Spare parts are to be understood in their ordinary commercial sense as extra or substitute parts of a machine, and an item must first be a part of machinery before it can qualify as a spare part. On that basis, windscreen wipers manufactured for diesel locomotives were treated as accessories rather than parts of machinery and were not liable to tax at the notified rate. The oil gauge was regarded as a part of machinery capable of substitution or replacement, and was therefore covered by the notification as a taxable spare part.

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Issues: Whether windscreen wipers and oil gauge manufactured and sold for use in diesel locomotives were spare parts of machinery liable to tax at the notified rate.

Analysis: The expression "spare parts" was understood in its ordinary commercial sense as extra or substitute parts of a machine, distinct from mere accessories. An article must first be a part of machinery before it can be treated as a spare part. On that basis, windscreen wipers, not being machinery or a part of machinery, could not be treated as spare parts of machinery. The oil gauge, however, was treated as a part of machinery capable of substitution or replacement and therefore within the notification.

Conclusion: Windscreen wipers were not taxable as spare parts of machinery, while the oil gauge was taxable as a spare part of machinery.

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