Specific tariff entry for switch board spare parts prevails over general entry where wooden boards are integral manufacturing components.

Wooden boards used in the manufacture of switch boards, and not shown to be separately sold as independent goods, were classifiable as spare parts or accessories of switch boards under entry 113 of Schedule II-A of the Gujarat Sales Tax Act, 1969. The specific entry covering transformers, switch gears, switch boards and their spare parts and accessories prevailed over the general entry 41 on the facts found, so the goods were not taxable under the residual entry. The classification question was thus answered in favour of the dealer and against the revenue.

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Issues: Whether wooden boards used for manufacturing switch boards were liable to tax under entry 113 of Schedule II-A of the Gujarat Sales Tax Act, 1969 as spare parts and accessories of switch boards, or under entry 41 of Schedule II-A.

Analysis: The wooden boards were used in the manufacture of switch boards and were not shown to be independently sold as separate goods. On that basis, they could be treated as spare parts falling within entry 113, which specifically covers transformers, switch gears, switch boards and their spare parts and accessories. The general placement under entry 41 was therefore not warranted on the facts found.

Conclusion: The goods fell under entry 113 of Schedule II-A and not under entry 41; the question was answered in favour of the dealer and against the revenue.

Ratio Decidendi: Goods used as integral spare parts or accessories for a specifically described taxable article are classifiable under the specific entry covering that article and its spare parts, not under a general residual entry.

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