Machinery used in cloth manufacture includes essential humidifiers that maintain yarn strength and production continuity.

Industrial centrifugal humidifiers fitted with electric motors were treated as machinery used in the manufacture of cloth under Entry 15 of Schedule C of the Bombay Sales Tax Act, 1959. Applying a plain and natural construction, the HC held that equipment qualifies where it performs a mechanical role in converting raw material into finished goods and is essential to that process. Because the humidifiers maintained the humidity needed to improve yarn strength, prevent breakages, and keep ring frames functioning smoothly, they were found to be an essential and integral part of textile manufacturing, not merely ancillary equipment. They therefore fell within Entry 15 and not Entry 20.

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Issues: Whether industrial centrifugal humidifiers complete with electric motors are machinery used in the manufacture of cloth and, therefore, fall within Entry 15 of Schedule C of the Bombay Sales Tax Act, 1959, rather than Entry 20.

Analysis: Humidifiers were held to be machinery because they operated mechanically to generate and distribute the required humidity. The decisive question was whether they were used in the manufacture of cloth. On a plain and natural construction of the expression, machinery that plays a role in converting raw material into finished goods and is essential to that process falls within the entry. The humidifiers maintained humidity necessary to improve yarn strength, prevent breakages, and ensure smooth functioning of the ring frames. They were treated as an essential and integral part of the textile manufacturing process and not as merely ancillary equipment.

Conclusion: The humidifiers were held to be machinery used in the manufacture of cloth and were therefore covered by Entry 15 of Schedule C. They did not fall under Entry 20.

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