Electronic goods classification controls where a computer-controlled copier fits the broader tariff entry over a specific description.

A fully computer-controlled electronic plain paper copier machine was treated as an electronic good under Entry 97(D) of Schedule II-A to the Gujarat Sales Tax Act, 1969. The court reasoned that Entry 97(D) covered electronic goods not falling within the narrower sub-entries, and the machine, together with its component parts and spare parts, fit that description. The specific wording of Entry 95 did not override the broader electronic goods classification on the facts found. Classification was therefore upheld under Entry 97(D), not Entry 95, in favour of the assessee and against the revenue.

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Issues: Whether a fully computer-controlled electronic plain paper copier machine was classifiable under Entry 95 of Schedule II-A to the Gujarat Sales Tax Act, 1969 or under Entry 97(D) of Schedule II-A as electronic goods.

Analysis: Entry 97 covered electronic goods, and sub-entry (D) applied to all other electronic goods not falling within sub-entries (A), (B) or (C). The machine in question was found to be an electronic good, and its component parts and spare parts were also treated as falling within Entry 97(D). The specific description in Entry 95 did not displace the classification under the electronic goods entry on the facts found.

Conclusion: The machine was correctly held to fall under Entry 97(D) of Schedule II-A and not under Entry 95. The question was answered in favour of the assessee and against the revenue.

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