Tax classification depends on the goods as sold, and thin stainless steel strips were not motor vehicle components.

Tax classification turned on the character of the goods as sold, not on the intended end use of the raw material. Thin stainless steel strips marketed by the assessee required further processing and addition of other articles before they could become wiper blades, so they were not component parts of motor vehicles in their sale form. The allotment order and invoices did not alter the nature of the goods actually sold. The strips were therefore correctly assessable as stainless steel articles under item 109 of the First Schedule.

---

---

Issues: Whether stainless steel strips manufactured from allotted stainless steel sheets were classifiable as component parts of motor vehicles falling under item 3 of the First Schedule, or as stainless steel articles falling under item 109 of the First Schedule to the Tamil Nadu General Sales Tax Act.

Analysis: The decisive question was the character of the goods in the form in which they were sold. The materials on record showed that the assessee sold only thin stainless steel strips, which could not be straightaway used as wiper blades and required further processing and addition of other articles before they could become motor vehicle components. Tax liability had to be determined by the nature of the article actually marketed, not by the purpose for which raw materials were allotted or by the intended end use of the manufacture. Since the goods sold were not themselves wiper arm blades and could not be treated as automobile parts in their marketed form, the reliance placed on the allotment order and invoices was insufficient to shift the classification.

Conclusion: The stainless steel strips were not component parts of motor vehicles and were correctly assessable under item 109 of the First Schedule.

---