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Issues: Whether super enamelled copper winding wire was covered by entry 16(2) of Schedule II, Part A to the Gujarat Sales Tax Act, 1969 as a spare part of an electric motor, or by entry 41 of that Schedule as electric goods.
Analysis: The wire was specially adapted for use in electric motors and was not an article of general use. Though it had to be cut and wound into coils before being fitted into a motor, that process did not destroy its identity or commercial character. A spare part need not be directly insertable without any further preparation if it is a distinguishable and replaceable part of the machine. The wire, when used in coil form, remained a distinct part of the motor used for creating the magnetic field and was commercially understood as such. It was therefore not merely raw material or an ordinary copper wire falling under the general entry for electric goods.
Conclusion: Super enamelled copper winding wire was held to be a spare part of an electric motor falling under entry 16(2) of Schedule II, Part A, and not under entry 41.
Ratio Decidendi: An article specially adapted for and commercially identified as a distinguishable part of a machine may be treated as a spare part even if it requires further processing before installation, provided it retains its distinct identity and function.