Specific listing controls tax classification: capacitors qualify as electronic goods, and no further user test was needed.

Capacitors were treated as electronic goods eligible for concessional tax because the relevant Government Orders and revenue clarification adopted the Electronic Commission list for identifying such goods, and that list expressly included capacitors as an electronic component. Once specific inclusion in the adopted list was shown, the Tribunal could not insist on an operating principle or user test, and its remand on that basis was unsustainable. The issue was decided in favour of the assessee, with concessional rate of tax allowed and the contrary approach set aside.

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Issues: Whether capacitors are to be treated as electronic goods eligible for concessional rate of tax, and whether the Tribunal was justified in applying the operating principle or user test despite the item being specifically listed.

Analysis: The relevant Government Orders and the clarification issued by the Revenue adopted the list prepared by the Electronic Commission for determining electronic goods for concessional tax treatment. That list expressly included capacitors as an electronic component. Once the item found specific mention in the adopted list, no further inquiry into its operating principle, functioning, or user test was warranted. The Tribunal's remand on that basis was therefore unsustainable.

Conclusion: The issue is decided in favour of the assessee. Capacitors are entitled to concessional rate of tax as electronic goods, and the Tribunal's contrary approach was rightly interfered with.

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