Motor vehicle seat covers qualify as accessories, but the reduced sales tax rate did not apply retrospectively.

Seat covers for motor vehicles were held to be "accessories" because they are supplementary articles that add to the utility, convenience or appearance of the principal vehicle. Applying the relevant sales tax entry, the Court held that the later notifications reducing the rate for motor vehicle spare parts and accessories did not create ambiguity in the earlier entry or justify retrospective application of the concessional rate. Subsequent legislation could be used only to clarify a genuinely ambiguous provision, which was not shown here. The applicable rate for the period 1 April 1993 to 31 December 1993 therefore remained 15 per cent, and the assessee was not entitled to the reduced 6 per cent rate.

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Issues: Whether seat covers for motor vehicles fall within the expression "accessories" in the relevant sales tax entry and, if so, whether the applicable rate of tax for the period 1 April 1993 to 31 December 1993 was 15 per cent or 6 per cent.

Analysis: The relevant entry originally covered motor vehicle spare parts and accessories together at 15 per cent. A later notification reduced the rate for motor spare parts to 6 per cent, and a subsequent notification separately referred to motor vehicle spare parts and accessories at 6 per cent. On the meaning of "accessory", the Court adopted the settled understanding that an accessory is something supplementary or subordinate which adds to the utility, convenience, beauty, or effectiveness of the principal article. Seat covers for motor vehicles answer that description. The Court also held that the later notification did not show any ambiguity in the earlier entry or any legislative intention to apply the reduced rate retrospectively. Subsequent legislation can aid construction only where the earlier provision is genuinely ambiguous, which was not the case here.

Conclusion: Seat covers are accessories, and for the relevant period they were liable to tax at 15 per cent. The assessee was not entitled to the reduced rate of 6 per cent for that period.

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