Agricultural implement classification turns on common use in farming operations, not exclusive agricultural use, for sales tax purposes.

'Double plated rims' were treated as agricultural implements because they were commonly used in agricultural operations and had a direct connection with those operations; exclusive agricultural use was not required. Applying the similar language of the U.P. Sales Tax Act and the Central Sales Tax Act notifications, the article was not classifiable as unclassified goods under either statute. The HC therefore upheld assessment of the goods as agricultural implements under both taxing laws and set aside the Tribunal's contrary order.

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Issues: (i) Whether 'double plated rims' were liable to be taxed under the U.P. Sales Tax Act as agricultural implements and not as unclassified goods; (ii) Whether the same goods were liable to be taxed under the Central Sales Tax Act as agricultural implements and not as unclassified goods.

Issue (i): Whether 'double plated rims' were liable to be taxed under the U.P. Sales Tax Act as agricultural implements and not as unclassified goods.

Analysis: The relevant notifications under section 3-A of the U.P. Sales Tax Act, 1948 levied tax on agricultural implements other than those worked by human or animal power. The earlier exemption notification under section 4 of the Act, which contained an exhaustive list of implements worked by human or animal power, was held to be irrelevant to the present controversy. On the factual findings recorded by the appellate authority and the Tribunal in an earlier final order, the goods were used in vehicles driven by power and were commonly used in agricultural operations. The real test is not exclusive agricultural use, but common user and direct connection with agricultural operations.

Conclusion: 'Double plated rims' were held to be agricultural implements for the purpose of section 3-A of the U.P. Sales Tax Act, 1948 and were not liable to be assessed as unclassified goods.

Issue (ii): Whether the same goods were liable to be taxed under the Central Sales Tax Act as agricultural implements and not as unclassified goods.

Analysis: The notification issued under section 8(5) of the Central Sales Tax Act, 1956 used language substantially similar to the U.P. sales tax notification, levying tax on agricultural implements other than those worked by human or animal power. Since the goods were found to fall within that category for the State levy, the same reasoning applied to the Central levy as well. The impugned classification as unclassified goods was therefore unsustainable.

Conclusion: 'Double plated rims' were held to be taxable under the Central Sales Tax Act as agricultural implements and not as unclassified goods.

Final Conclusion: The revisions succeeded, the Tribunal's order was set aside, and the disputed goods were directed to be assessed as agricultural implements under both taxing statutes.

Ratio Decidendi: For sales tax classification, an article qualifies as an agricultural implement if it is commonly used in agricultural operations and is intimately and directly connected with those operations; exclusive use for agriculture is not required.

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