Electronic classification of microprocessor-controlled photocopiers prevails over mechanical description for trade tax purposes.

Fully automated photocopier machines controlled by microprocessors, microchips and electronic circuit boards were treated as electronic goods rather than duplicating machines for Central sales tax and U.P. trade tax classification. The Court accepted the undisputed factual position that the machines operated through programmed electronic control and held that this made them materially different from mechanical duplicators. It applied the Supreme Court's reasoning on microprocessor-controlled automated machines, and rejected contrary authorities and later administrative change for the relevant period. The alternative-remedy objection was not accepted because the dispute turned on undisputed facts and a pure question of classification.

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Issues: Whether fully automated photocopier machines controlled by microprocessors and microchips are to be classified as electronic goods, and not as duplicating machines, for purposes of Central sales tax and U.P. trade tax.

Analysis: The factual assertions that the petitioner's photocopiers operate through microprocessors, microchips, electronic circuit boards, and automated control systems were not specifically denied. The Court held that modern photocopiers represent an advanced electronic device whose functioning is governed by electronic current and programmed microprocessor control, making them materially different from mechanical duplicating machines. It further held that the Supreme Court's reasoning on microprocessor-controlled fully automated machines squarely applied, while the contrary authorities and the later administrative change could not displace the correct classification for the period in question. The plea of alternative remedy was not accepted because the controversy turned on undisputed facts and a pure question of classification.

Conclusion: The photocopier machines were held to be electronic goods and not duplicating machines, and the classification adopted by the revenue authorities was set aside.

Ratio Decidendi: A fully automated machine whose essential functions are controlled by microprocessor and microchip-based electronic systems is classifiable according to its electronic character, and not by a merely mechanical description, where the governing statutory entry supports such classification.

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