Classification of battery parts fails where the product is a primary cell, not a rechargeable storage battery.

Plastic covers used for carbon elements in AWC 2 cells were not classifiable as parts of electric storage batteries under Entry 3-A of the Tamil Nadu General Sales Tax Act, 1959, because the product was found to be a primary cell rather than a rechargeable storage battery. The relevant entry covered storage batteries and their parts, including containers, covers and plates, but that description applied only where the underlying product was a storage battery. As AWC 2 was consumed in use and not rechargeable by reversal of current, the plastic cover could not be treated as a taxable battery part merely because it functioned as a component or separator.

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Issues: Whether plastic covers used for covering carbon elements of AWC 2 cells were classifiable as parts of electric storage batteries under Entry 3-A of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959.

Analysis: The relevant entry covered electric storage batteries and parts thereof, including containers, covers and plates. The decisive question was whether the assessee's AWC 2 cells were storage batteries. On the evidence and accepted commercial meaning, AWC 2 was a primary cell and not a rechargeable secondary cell. A storage battery is rechargeable by reversal of current, whereas a primary cell is consumed in use and must be discarded. Since the assessee's product was only a primary battery, the plastic cover used for its carbon element could not be treated as a part of a storage battery merely because it acted as a separator or component of the cell.

Conclusion: The plastic covers were not covered by Entry 3-A and were not taxable as parts of storage batteries.

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