Specific machinery entry prevails over general electrical goods classification for generating set spare parts under entry tax law.

Electrical spare parts purchased for thermal generating sets used in captive power generation were treated as machinery under the entry tax law because the machinery entry was specific and included parts and accessories, while the electrical and electronic goods entry was general. Applying settled principles of taxing statute interpretation, the specific entry prevailed over the broader one. The Court also relied on prior authority treating diesel generating sets as machinery rather than electrical goods merely because they generate electricity. The entry tax levy at two per cent was therefore upheld against the assessee.

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Issues: Whether electrical spare parts purchased for thermal generating sets used for captive power generation were classifiable as machinery under the entry tax law and liable to entry tax at two per cent.

Analysis: The Court compared the competing entries for electrical and electronic goods on the one hand and machinery and parts and accessories on the other. It held that the machinery entry was a specific entry covering parts and accessories, whereas the electrical goods entry was general in nature. Applying settled principles of interpretation of taxing statutes, the Court treated the specific entry as controlling the broader entry. The Court also noticed prior authority that diesel generating sets are machinery and not electrical goods merely because they generate electricity.

Conclusion: The electrical spare parts for the generating sets were correctly assessed as machinery, and the levy of entry tax was upheld against the assessee.

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