Special entry prevails over general entry for stainless steel machinery parts under Tamil Nadu sales tax classification.

Stainless steel boiler components and spare parts used as parts and accessories of machinery were held to fall within the special machinery entry, not the general entry for articles made of stainless steel. The statutory scheme treated item 81 as the specific provision for machinery and its parts, while item 109 was a broader material-based entry. The later amendment to item 109, excluding parts and accessories covered by item 81, confirmed that such goods were intended for classification under item 81. The correct tax treatment therefore followed the special entry, and the broader stainless steel entry did not apply.

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Issues: Whether the sale turnover of stainless steel boiler components and spare parts fell under item 81 or item 109 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959, for the assessment year 1979-80.

Analysis: The goods were boiler components and spare parts made of stainless steel and were used as parts and accessories of machinery. Item 81 covered machinery worked by specified sources of power and the parts and accessories of such machinery, while item 109 was a general entry for articles made of stainless steel. The subsequent amendment to item 109 expressly excluded parts and accessories of stainless steel falling under item 81, showing that such items were intended to be classified under item 81 rather than item 109. A special entry governs over a general entry, and the same article cannot be subjected to one rate as machinery and another as its spare parts where the statutory scheme places the parts and accessories within the machinery entry.

Conclusion: The disputed turnover was correctly classified under item 81 of the First Schedule and taxed at 6 per cent; the classification under item 109 was rejected.

Ratio Decidendi: Where parts and accessories of machinery are specifically covered by a special entry, they are to be classified under that entry and not under a broader general entry for articles made of the same material.

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