Integral railway components fall under the specific VAT entry, not the residuary rate, where the statute includes "part thereof".

Batteries manufactured to Railway specifications and supplied for use in railway engines, coaches and wagons were treated as integral components of those units because the statutory entry covered railway coaches, engines, wagons and "part thereof". On that construction, the batteries fell within the specific schedule entry rather than the residuary classification, since they were necessary for operation, lighting and air-conditioning of the railway equipment. The practical effect was classification under Entry 76 of the Third Schedule to the Karnataka Value Added Tax Act, 2003, attracting tax at 4% instead of the higher residuary rate.

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Issues: Whether batteries manufactured as per the specifications of the Railways and sold to them are to be treated as part of railway coaches, engines and wagons falling under Entry 76 of the Third Schedule to the Karnataka Value Added Tax Act, 2003, and taxable at 4% rather than under the residuary entry at 12.5%.

Analysis: Entry 76 of the Third Schedule covered railway coaches, engines, wagons and part thereof. The batteries supplied to the Railways were specially manufactured for use in railway engines, coaches and wagons, and were necessary for their operation, lighting and air-conditioning. The inclusion of the words "part thereof" showed a legislative intent to cover integral components required for the functioning of the railway coaches, engines and wagons. Applying that construction, the batteries were held to be an integral part of the railway equipment and not merely separate unscheduled goods. The residuary entry could apply only if the goods did not fall within a specific entry.

Conclusion: The batteries sold to the Railways fell within Entry 76 of the Third Schedule and were liable to tax at 4% under Section 4(1)(a) of the Karnataka Value Added Tax Act, 2003. The levy at 12.5% under the residuary entry was not justified.

Ratio Decidendi: Where the statutory entry expressly includes "part thereof", goods that constitute an integral and necessary component of the specified railway equipment are classifiable under that entry and not under the residuary provision.

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