Industrial trolley classification turns on machinery and accessory tests, and falls under the residuary entry.

A two-side open wooden industrial trolley used in textile processing was held not to be "machinery" because it had no mechanical contrivance of its own and operated only as a hand-moved receptacle, assessed in ordinary commercial understanding. It was also not an "accessory" of machinery, because it was neither an adjunct nor an accompaniment to the processing machinery in the legally relevant sense of contributing to its convenient use or effectiveness. The trolley was therefore classified under the residuary entry 13 of Schedule III, and not under entry 16(1) of Schedule II, Part A or entry 36 of the notification under the Gujarat Sales Tax Act, 1969.

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Issues: Whether a two-side open wooden industrial trolley used in textile processing is "machinery" or an "accessory" of machinery so as to fall under entry 16(1) of Schedule II, Part A or entry 36 of the notification under section 49(2) of the Gujarat Sales Tax Act, 1969, or whether it is covered by the residuary entry 13 of Schedule III.

Analysis: The term "machinery" was held to require something more than a mere receptacle or a solid structure mounted on wheels; the item must consist of mechanical contrivances operating in interdependent action to produce a specific result, judged in ordinary commercial understanding and on the facts of each case. Applying that test, the trolley in question, though specially designed for textile use and useful in moving cloth to and from machines, had no mechanical contrivance of its own and could function only as a hand-moved receptacle. The further test for "accessory" also failed because the trolley was not an adjunct, accompaniment, or addition to the processing machinery that contributed to its convenient use or effectiveness in the relevant legal sense.

Conclusion: The trolley was neither machinery nor an accessory of machinery and was correctly classified under the residuary entry 13 of Schedule III, not under entry 16(1) of Schedule II, Part A or entry 36 of the notification.

Ratio Decidendi: An article will be treated as machinery only if it is a mechanical contrivance operating through interdependent parts to produce a definite result, and it will be an accessory only if it is an adjunct or accompaniment to the main machinery in the legally relevant sense of convenient use or effectiveness.

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