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Issues: Whether road traffic signalling equipment including blinkers are electrical goods within entry No. 18 of the First Schedule and taxable at the higher rate applicable to electrical goods.
Analysis: The expression "electrical goods" was held to require more than the mere fact that an article can function only with electricity. The article must also, by its intrinsic nature, be understood in trade and by persons conversant with the subject-matter as electrical goods. Applying that test, road traffic signalling equipment and blinkers, though electrically operated and useless without electrical energy, are specialised articles made for a limited purpose and are not normally bought or sold as electrical goods in commercial circles. The Court approved the twin-test approach that combines functional dependence on electricity with commercial and intrinsic character.
Conclusion: Road traffic signalling equipment including blinkers are not electrical goods for the purpose of the relevant schedule entry, and the question was answered against the Revenue and in favour of the assessee.