Accessory test for diesel engines: a radiator can qualify as an accessory if it aids and makes the engine more effective.

Radiators sold for use in motor vehicles were examined under a concession notification for parts and accessories of diesel engines used in such vehicles. The key issue was whether a radiator could be treated as an accessory, since it was not essential to engine operation but supported and improved engine performance by cooling it. The court treated "accessory" as a broad term covering an article that aids, assists, or makes the principal thing more effective, and held that the radiator was a subordinate adjunct to the diesel engine. On that basis, the concessional rate applied and the sales were taxable at 8 per cent.

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Issues: Whether radiators sold for use in motor vehicles were covered by the concession granted to parts and accessories of diesel engines used in motor vehicles, so as to attract tax at 8 per cent instead of 12 per cent.

Analysis: The notifications applied where the goods were both a part or accessory of a diesel engine and were used in motor vehicles. There was no dispute that radiators were used in motor vehicles. The real question was whether a radiator was a part or accessory of the diesel engine. A radiator could not be treated as a part of the engine because the engine could operate without it, but the word "accessory" had a wide meaning and covered an article which aided, assisted, or made the principal thing more effective. On that approach, a radiator enhanced the effectiveness of the engine, assisted in its functioning by cooling it, and was a subordinate adjunct to it.

Conclusion: A radiator is an accessory of the diesel engine and is covered by the notifications, so the sales are taxable only at 8 per cent.

Ratio Decidendi: An article that is not essential for the operation of a machine may still be its accessory if it aids, assists, or makes the machine more effective, and a concession notification covering accessories applies on that basis.

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