Stencil paper classification turns on general paper entry, not duplicating machine accessories, under sales tax law.

Stencil paper is classifiable as paper of all kinds under the general goods entry because it is not expressly covered by the machinery-accessories entry. A mere functional connection with duplicating machines does not make stencil paper an accessory of those machines. Where one entry uses broad language to include paper of all kinds and other paper not specifically mentioned elsewhere, the goods fall within that general entry unless a more specific entry clearly applies. Accordingly, stencil paper falls under Entry 143 of the Andhra Pradesh General Sales Tax Act, 1957 and not under the entry for duplicating machine parts and accessories.

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Issues: Whether stencil paper is taxable under Entry 12 of the First Schedule to the Andhra Pradesh General Sales Tax Act, 1957 as an accessory of duplicating machines, or under Entry 143 of the First Schedule as paper of all kinds.

Analysis: Entry 12 covers typewriters, teleprinters, duplicating machines and their parts and accessories. Applying the distinction between a part and an accessory, stencil paper was held not to be an accessory of a duplicating machine. Entry 143, however, is couched in very wide language and covers paper of all kinds, including all other kinds of paper and paper board not otherwise specifically mentioned. As stencil paper is not specifically mentioned in any other entry, it falls within Entry 143.

Conclusion: Stencil paper is classifiable under Entry 143 and not under Entry 12.

Ratio Decidendi: Where a goods entry uses broad language covering paper of all kinds and all other kinds of paper not specifically mentioned elsewhere, the goods will fall within that general entry unless they are expressly brought under a more specific entry; a mere functional connection with machinery does not make them an accessory.

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