Voltage stabilizer classification as electronic goods upheld on its electronic components and voltage-regulating function.

A voltage stabilizer was held classifiable as electronic goods rather than electrical goods under the competing tariff entries. The Court construed the entries by their language and scope, noting that goods falling under the electrical category are those usable only with electrical energy, whereas the electronic category covers devices operating through electronic components and principles. Accepting the Tribunal's factual findings on the stabilizer's nature, components, and working, the Court held that the device regulated voltage for appliances and was not concerned with generation, distribution, or transmission of electricity. The Tribunal's classification was upheld and the Revenue's challenge failed.

---

---

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

Analysis: The relevant entries were construed by their language and scope. Entry 16 covered goods whose use could not be had except with the application of electrical energy, while Entry 74 dealt with electronic goods, including the residuary category of other electronic goods. The Court noted that an electronic device may be an electrical device, but an electrical device is not necessarily an electronic device. On the facts found by the Tribunal, the voltage stabilizer operated through electronic components and principles, and its use was for regulating voltage for appliances rather than generation, distribution, or transmission of electricity. The Tribunal's factual findings on the nature, components, and working of the stabilizer were accepted.

Conclusion: The voltage stabilizer is electronic goods and not electrical goods. The classification adopted by the Tribunal was upheld and the Revenue's challenge failed.

---