Integral battery parts are not accessories or spare parts; restrictive tariff wording limits classification to listed items.

Battery plates and battery covers were held to be integral and essential parts of an accumulator, because the battery cannot function without them and replacement would alter the article's identity. On that reasoning, they are not "accessories" or "spare parts" under entry 3 of the Andhra Pradesh General Sales Tax Act. Entry 38 was treated as a restrictive and exhaustive list, since the words "that is to say" confine it to the items specifically enumerated. The practical effect was that the goods could not be classified under either entry and were to be assessed as unclassified goods.

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Issues: Whether battery plates and battery covers are taxable as accessories or spare parts of accumulators under entry 3 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957, or fall under entry 38, or remain unclassified goods.

Analysis: The expression "accessories" denotes something additional or adjunct and not an essential or integral part. Battery plates and battery covers were found to be component and essential parts of a battery, without which the battery cannot function, and their replacement would alter the identity of the article; they were therefore not accessories or spare parts. The expression "spare parts" was treated as referring to parts kept for replacement or emergency use, and not to integral component parts. Entry 38 was construed as a restrictive and exhaustive enumeration because the words "that is to say" limit the general description to the items specifically listed in sub-entries (i) to (v).

Conclusion: Battery plates and battery covers are neither accessories nor spare parts under entry 3 and do not fall within entry 38; they are liable to be treated as unclassified goods.

Final Conclusion: The revisional orders classifying the goods under entry 3 were unsustainable, and the assessee was entitled to have the items assessed as unclassified goods.

Ratio Decidendi: A part that is integral to the functioning and identity of the article is not an accessory or spare part, and a general tariff entry restricted by the phrase "that is to say" cannot extend beyond the specifically enumerated items.

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