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Issues: Whether carbon bushes were taxable as electrical goods, including as accessories or component parts thereof, or as unclassified items under the relevant sales tax notifications.
Analysis: The relevant notifications treating electrical goods as a taxable category were construed to include accessories and components. Carbon bushes were found to be used in electrical machinery and to function as accessories for electrical goods. The reasoning accepted that the mere fact that such goods may be used in pumps or other equipment does not take them out of the electrical goods category where their commercial identity and use bring them within the inclusive entry. Authorities treating unrelated articles as outside the notification were distinguished on facts.
Conclusion: Carbon bushes were held taxable as electrical goods and not as unclassified items.
Final Conclusion: The revisions succeeded and the assessment was restored to the extent that carbon bushes fell within the taxable category of electrical goods under the applicable notifications.
Ratio Decidendi: Where the taxing notification includes accessories and component parts of electrical goods, an article commercially and functionally used as an accessory in electrical equipment is classifiable as electrical goods even if it may also be capable of other uses.