Classification of voltage stabilisers under sales tax law: taxable goods, not accessories to exempt electrical energy

Voltage stabilisers were held to be taxable goods under the relevant First Schedule entry because they regulate the supply of electrical energy rather than form part of electrical energy itself. The exemption for electrical energy did not extend to devices that merely facilitate convenient and regulated use of electricity. The specific entry covering voltage stabilisers prevailed over the alternative claim of classification as an accessory to electrical energy, and the goods were also rejected from item 83 because they were not machinery propelled or operated by electricity.

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Issues: Whether voltage stabilisers manufactured and sold by the assessees were exempt as accessories to electrical energy, or were classifiable as taxable goods under the relevant entries in the First Schedule.

Analysis: The liability turned on the true character of voltage stabilisers. Electrical energy is the exempted commodity under section 8, not devices used for regulating its supply. Voltage stabilisers are used for convenient and regulated use of electricity for appliances, but they do not become accessories to electrical energy merely because they facilitate its use. The specific entry in item 38(v) of the First Schedule was wide enough to cover voltage stabilisers, and the alternative contention that they fell under item 83 was rejected because such goods are not machinery propelled or operated by electricity; they only regulate the supply of electrical energy.

Conclusion: The voltage stabilisers were taxable under the relevant First Schedule entry and were not exempt as accessories to electrical energy or classifiable under item 83.

Ratio Decidendi: A device used to regulate the supply of electrical energy is not an accessory to electrical energy itself, and where a specific taxable entry squarely covers the goods, that entry prevails over a claimed exemption or an inapposite classification.

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