Cartridges as computer accessories: inkjet and toner cartridges fall within the lower-rate IT goods entry.

Inkjet cartridges and toner cartridges were treated as integral to the functioning of printers and, by common-sense trade understanding, as parts and accessories of computer systems and peripherals under the Assam Value Added Tax Act, 2003. The broader wording of the IT goods entry was held sufficient to include them, and a specific exclusion of toner and cartridges in another entry did not displace that wider classification. As a result, the cartridges fell within the lower-rate entry and not the residuary higher-rate entry.

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Issues: Whether inkjet cartridges and toner cartridges fall within the entry for parts and accessories of computer systems and peripherals under the Assam Value Added Tax Act, 2003, or are taxable under the residuary higher-rate entry.

Analysis: The entries were construed on a common-sense understanding of goods as used in trade. Printers were accepted as computer peripherals covered by the relevant lower-rate entry, and the cartridges were treated as integral to the functioning of the printer. The reasoning drew support from the principle that an accessory is an aid or addition and from the view that similar goods had been held to be parts and accessories in comparable statutory entries. The wider wording of the IT goods entry was held sufficient to include the cartridges, and the specific exclusion of toner and cartridges in another entry did not control the broader entry for parts and accessories of computer systems and peripherals.

Conclusion: Inkjet cartridges and toner cartridges were held to be covered by the lower-rate entry for parts and accessories of computer systems and peripherals, and not by the residuary higher-rate entry.

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