Accessory classification for miniature filament bulbs fails where the goods are used across multiple devices, not just motor vehicles.

Miniature filament bulbs were held not to be accessories of motor vehicles because an accessory must be specially adapted for, and ordinarily confined to, the relevant use. The bulbs were found to have multiple uses in radios, torches, flashlights and other electrical devices, and were not exclusively adapted for motor vehicles. The notification also excluded torch bulbs and filament lighting bulbs from the electrical goods entry without placing them elsewhere. They were therefore treated as unclassified items and taxed at the lower rate.

---

---

Issues: Whether miniature filament bulbs manufactured and sold by the dealer were accessories of motor vehicles and therefore classifiable under the entry relating to motor vehicles, or whether they were unclassified items.

Analysis: The relevant notification excluded torch bulbs and filament lighting bulbs from the electrical goods entry and did not place them in any other entry. The bulbs in question were found not to be exclusively used in motor vehicles, but to have multiple uses in different appliances such as radios, torches, flash lights and other electrical devices. An article can be treated as an accessory only where it is specially adapted for and ordinarily confined to the relevant use, and the mere fact that it may add to beauty or convenience in one use does not make it an accessory of that use alone. On the facts found by the Tribunal, the bulbs were not exclusively adapted for motor vehicles.

Conclusion: Miniature filament bulbs were not accessories of motor vehicles and were rightly treated as unclassified items attracting tax at the lower rate.

---