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Issues: Whether electric furnaces were "electrical goods" within item 18 of Schedule I of the Bengal Finance (Sales Tax) Act, 1941, and therefore liable to tax at the higher rate.
Analysis: The expression "electrical goods" was not to be confined to articles which merely work on electricity. Prior decisions applying a narrow functional test were examined, but the controlling inquiry was held to be the meaning of the expression in common parlance, subject to the statutory context. The exclusion in item 18 of "electrical plant", "equipment" and their accessories showed that the draftsman used the expression in a wider sense than ordinary usage. An electric furnace, whether regarded as plant or equipment, fell within that wider statutory concept.
Conclusion: Electric furnaces were held to be electrical goods under item 18 and were liable to tax at the higher rate.
Ratio Decidendi: The meaning of "electrical goods" depends on common parlance, but the statutory context may enlarge that meaning; where the entry itself indicates a wide legislative concept, articles that answer that wider description fall within it even if they are also plant or equipment.