Exemption for machine components fails where toner and developer are separate goods, not integral parts of the photocopier.

Toner and developer sold with a photocopier machine were held to be separate items, not integral constituent parts of the machine. The photocopier turnover was covered by the eligibility certificate, but exemption for toner and developer depended on whether they formed part of the exempted machinery. Applying its earlier decision on the same issue, the HC concluded that the goods were not part of the photocopier machine, so the exemption claim failed. The governing principle is that exemption is available only where the goods claimed are shown to be integral parts of the exempted machinery, not merely items sold alongside it.

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Issues: Whether toner and developer sold along with a photocopier machine were parts of the photocopier machine and therefore eligible for exemption under the trade tax .

Analysis: The turnover of the manufactured photocopier machine was covered by the eligibility certificate, but the claim for exemption in respect of toner and developer depended on whether those items could be treated as constituent parts of the machine. Following the earlier decision of the Court on the same question, toner and developer were held to be separate items and not integral parts of the photocopier machine. On that basis, the exemption claim could not be accepted.

Conclusion: Toner and developer are not parts of the photocopier machine and are not eligible for exemption.

Ratio Decidendi: For exemption to apply, the goods claimed must be shown to be integral parts of the exempted machinery and not merely items sold along with it.

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