Motor vehicle batteries as component parts remain under the specific tax entry, not the general electrical-goods category.

Motor vehicle batteries were treated as component parts under the specific sales tax notification governing motor vehicles, chassis and parts, rather than as general electrical goods. The analysis turned on the construction of successive notifications: the specific treatment for component parts and articles adapted for use as parts or accessories continued to apply, and a later electrical-goods entry did not displace that specific category. A battery, though not an accessory or spare part, was described as necessary for the completion and functioning of a motor vehicle and therefore within the component-parts entry. Earlier contrary observations were treated as obiter and not controlling.

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Issues: Whether motor vehicle batteries were taxable at 3% under the applicable notification for component parts of motor vehicles, or at 7% as electrical goods or electrical equipment.

Analysis: The taxability turned on the proper construction of the successive sales tax notifications governing motor vehicles, their chassis, component parts, accessories and electrical goods. The earlier notifications showed that component parts and articles adapted for use as parts and accessories were treated as a distinct category, and mere inclusion of batteries in a later electrical-goods entry did not eliminate the specific treatment available under the motor-vehicle notifications. A battery was not an accessory or spare part, but it was necessary for the completion and functioning of a motor vehicle and therefore constituted a component part. The earlier contrary observations were treated as obiter and not decisive of the present controversy. On that construction, the specific entry applicable to motor vehicle batteries continued to govern them.

Conclusion: Motor vehicle batteries were taxable at 3% under the applicable notification and not at 7%.

Ratio Decidendi: Where a commodity answers the description of a specific component part under a special notification, it cannot be assessed under a more general electrical-goods entry merely because it may also have an electrical character.

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