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Issues: Whether radiators used in the manufacture of transformers fall within entry 38 of the First Schedule to the Andhra Pradesh General Sales Tax Act as electrical goods or accessories, or whether they are taxable as general goods.
Analysis: Radiators used in transformers were held not to be electrical goods, instruments, apparatus or appliances in their own right. They were found to be meant for cooling the transformer and to form an integral and essential part of the transformer. On the settled meaning of "accessories", a component that is integral and indispensable to the working of the principal item cannot be treated as an accessory. The radiator therefore did not qualify for classification under entry 38.
Conclusion: The radiators were not taxable under entry 38 as electrical goods or accessories, and were correctly liable to tax as general goods under section 5(1) of the Act.
Final Conclusion: The revision failed and the assessment treating the radiators as general goods was upheld.
Ratio Decidendi: A component that is an integral and essential part of the principal goods cannot be treated as an accessory for tariff classification, and must be classified according to its own taxable entry if it does not independently fall within the specific goods category.