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Issues: Whether hydraulic door closers are classifiable under Entry 92 of Schedule IV as fitting for doors, or under the residuary entry in Schedule V.
Analysis: The disputed goods were examined with reference to the wording of Entry 92, which enumerates various door fittings such as hinges, handles, stoppers, springs, magic eyes, trolley wheels, pulleys and holdfasts, but does not expressly mention hydraulic door closers. Applying the common parlance test, the Court noted that a dealer or consumer would ordinarily understand door fittings to mean items of the same kind as those specifically listed in the entry, and not a separate mechanical device like a hydraulic door closer. The Court also relied on the reasoning that such a closer is an automatic mechanical arrangement that retards the closing of a door and is more appropriately treated as machinery than as a mere fitting for doors.
Conclusion: Hydraulic door closers do not fall within Entry 92 of Schedule IV and were correctly assessed under the residuary entry in Schedule V; the assessee's challenge failed.