Voltage stabilizers classified as electronic goods under tax law after functional and component-based analysis.

An automatic voltage stabilizer was treated as electronic goods, not electrical goods, for tax classification under the relevant U.P. Trade Tax entries. The Court focused on the product's nature, components, purpose and working, noting that it was made of electronic components and operated on electronic principles to regulate voltage. The presence of some electrical parts did not by itself make the commodity electrical goods. Applying that functional test, the classification was upheld in favour of treating the stabilizer as electronic goods.

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Issues: Whether a voltage stabilizer is classifiable as electrical goods under entry 16 of the Schedule to the U.P. Trade Tax Act, 1948, or as electronic goods under entry 74(f) of Notification No. 1223 dated 31 March 1992 and the corresponding later entry.

Analysis: Entry 16 covered all electrical goods, instruments, apparatus and articles whose use depended on electrical energy. Entry 74 dealt with electronic goods not otherwise specified. On the material before the Court, a voltage stabilizer was found to be a device made up of electronic components and used for regulating voltage through electronic principles. The Court accepted the Tribunal's reasoning that the presence of some electrical components did not by itself make the commodity electrical goods. Applying the nature, components, purpose and working of the product, the Court held that an automatic voltage stabilizer is understood as electronic goods for tax classification purposes.

Conclusion: Voltage stabilizers are electronic goods and not electrical goods. The tax classification in favour of the assessee was upheld.

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