Harvester belts used only in agricultural machines fall within the specific exemption for implements and parts.

Specially manufactured harvester belts used only in harvesters were treated as parts or accessories of agricultural implements and therefore within the specific exemption for agricultural implements, parts, accessories and attachments. The broader earlier entry taxing "belting of all kinds" did not prevail over that specific later exemption because the belts were hard, distinct articles with no use other than in harvesters. The exemption claim was upheld and the tax revision failed.

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Issues: Whether harvester belts manufactured and sold by the dealer were covered by the exemption for agricultural implements, parts, accessories and attachments thereof, or were taxable as "belting of all kinds" under the earlier taxing notification.

Analysis: The turnover related to special belts made only for harvesters. The factual findings recorded by the authorities and affirmed in revision showed that the belts were of a hard and distinct nature, could not be used as fan belts or V-belts, and had no use other than in harvesters. On that basis, the commodity was treated as a part or accessory of an agricultural implement within the later exemption notification. The earlier entry taxing "belting of all kinds" was held not to control a special article covered by the specific exemption for agricultural implements and their parts, accessories and attachments. The cited decision on belting was distinguished on facts, and the later exemption was held applicable to the commodity in question.

Conclusion: The belts were exempt as parts of agricultural implements, and the revision failed.

Final Conclusion: The tax revision was dismissed, with the exemption claim of the assessee upheld and costs imposed.

Ratio Decidendi: A specially manufactured article used only as a part or accessory of an exempt agricultural implement is entitled to the specific exemption for such implements, and an earlier general taxing entry does not prevail over that specific later exemption.

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