Functional test for machinery classification brings hydraulic door closers within sales tax entry coverage.

Hydraulic door closers were held to fall within the ordinary and functional meaning of "machinery" because they are organised mechanical contrivances of interrelated parts performing a definite function. The court applied a practical test based on dictionary meaning and prior exposition, asking whether the article operates as a mechanical device rather than as simple hardware. A door closer that uses a hydraulic damper to retard and regulate door closure was therefore treated as machinery, and its commercial description could not override its true functional character. On that basis, the goods were brought within entry 20 of the Second Schedule to the Karnataka Sales Tax Act, 1957, making tax leviable under that entry.

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Issues: Whether door closers sold by the assessee fall within the expression "machinery" under entry 20 of the Second Schedule to the Karnataka Sales Tax Act, 1957.

Analysis: The expression "machinery" was construed in its ordinary and practical sense, with reference to settled dictionary meaning and prior judicial exposition. The relevant test is whether the article consists of an organised arrangement of parts operating together as a mechanical contrivance to perform a definite function. Applying that approach, a hydraulic door closer was found to be an assembled device with multiple components and a specific mechanical function, namely, to retard and regulate the closing of doors by means of a hydraulic damper. The article was therefore not treated as a mere hinge or simple hardware item, and commercial description could not displace its true functional character.

Conclusion: Door closers of the kind in question are machinery within entry 20 of the Second Schedule to the Karnataka Sales Tax Act, 1957, and tax was rightly leviable under that entry.

Ratio Decidendi: An article is "machinery" when, in its ordinary and functional sense, it is an organised mechanical contrivance of interrelated parts performing a specific mechanical operation, regardless of the mode by which the power or force is applied.

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