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Issues: Whether customised rexine seat covers and related fittings for motor cars were "articles adapted for use as parts and accessories" of motor vehicles under entry 58(2) of Schedule C to the Bombay Sales Tax Act, 1959, or fell under the residuary entry 22 of Schedule E.
Analysis: The articles were made to the measurements of specific motor vehicles and were intended for use only in motor cars. The Court applied the ordinary commercial understanding of "accessory" and noted that an accessory need not be essential to the functioning of the main article; it is enough if it adds to its beauty, convenience, comfort, or effectiveness. The seat covers, door covers, cowl pads, and rear glass shelf covers enhanced comfort, preservation, and appearance of the motor vehicles and were therefore accessories of the vehicles themselves. The Court distinguished authorities dealing with accessories of individual parts and held that the present articles were directly accessories of motor vehicles.
Conclusion: The articles fell within entry 58(2) of Schedule C and not within the residuary entry 22 of Schedule E; the reference was answered against the assessee.