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TMI Blog2014 (9) TMI 30X X X X Extracts X X X X X X X X Extracts X X X X ..... ng of another machinery or an accessory because of the enhanced utility of another machinery or machinery with which in combination with its use enhanced or even that it can be such a tool without which the main machinery may even become disfunctional, as in the case of a drilling machine, which is not of much use without a drilling bit. In a situation of such nature, drilling machine or drilling bit or blade or any other such accessory may even assume the role of being a part of the main machinery. It is, therefore, we are of the opinion that there cannot be a generalization or an examination de hors the particular product in combination with the machinery with which makes use of the goods or product. - Order of tribunal set aside - Decided in favor of Revenue. Levy of entry tax on drill-bits which are also called as machinery tools and wear parts such as drill-bits, reamers, cutters, etc. - Held that:- The fact of the notified goods coming into local area and the purpose for which it is brought are both significant and it is a combined operation of the two, which completes the charges in respect of the specified goods. Therefore, assuming that use, application or consumption, etc ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... caused entry into the local area for use, consumption or sale. The Tribunal so opined and reversed the orders of the assessing authority and the first appellate authority, who had taken the view that these goods brought into the local area by the assessee for use, consumption or sale, attract the tax as goods covered under entry 52 of the First Schedule to the Act. Five appeals before the Tribunal related to the assessment years 2001-02, 2002-03, 2003,04, 2004-05 and 2005-06. This court at the time of admission of these revision petitions had formulated the following questions of law for examination, which arise out of the order of the Tribunal questioning the correctness or otherwise are required to be examined: (i) Whether the Tribunal was justified in allowing the appeal of the respondent particularly in the facts and circumstances of the case? (ii) Whether the Tribunal is right in holding that the part and accessories are consumable contrary to the view taken by the honourable Supreme Court in the case of Addison & Co. [2009] 23 VST 5 (SC)? 3. The assessee is a company, engaged in manufacture and sale of machines and machine tools. It has its manufacturing unit at Chennai ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... me to be affirmed by the honourable Supreme Court in the order of February 26, 2009 (Addison & Co. Ltd. v. State of Karnataka [2009] 23 VST 5 (SC)) ray of hope was left behind for the assessee by further observing that contention which was sought to be raised before the Supreme Court to the effect that subject goods are consumables and therefore not accessories/parts of machines, if it is so, could be raised before the assessing authority and if so raised the assessee has to examine it in accordance with law, has been pressed into service by the assessee for taking up such contentions based on the observations of the Supreme Court in the pending appeals before the Tribunal, relating to the assessment years 2001-02, 2002-03, 2003-04, 2004-05 and 2005-06. 8. The assessee had gone through the stages of the assessing authority and the first appellate authority which had opined that the assessee was liable in respect of the goods in question for payment of tax under the Act as they had opined so for the earlier assessment years and the assessee nevertheless had been pursuing the matter by way of further appeal before the Tribunal and such appeals were pending before the Tribunal. The j ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Radhika Sriranjani and the revision petitioner is represented by Smt. Sujatha, learned Additional Government Advocate. 12. These revision petitions have been heard together with other revision petitions involving the question of taxability or otherwise of items or goods which are similar in nature, like chipper knives, cutters, drill bits, etc., in CRP No. 147 of 2011, machine tools like drill bits, reamers, cutters, etc., in CRP No. 295 of 2010 and CRP No. 333 of 2010, drill bits, reamers, cutters, taps, etc., in CRP No. 294 of 2010 and CRP No. 338 of 2010, drill bits, reamers, taps and cutters, etc., in CRP No. 235 of 2010 and CRP No. 289 of 2010, twist drills, cutters, reamers, taps, etc., in CRP No. 293 of 2010 and CRP Nos. 334-337 of 2010, drill bits, reamers, cutters, etc., in CRP Nos. 292 and 308-309 of 2010 and in CRP Nos. 165 and 166 of 2011. 13. The learned counsel appearing for the assessee have put forth several contentions calling in aid several judgments of the honourable Supreme Court and this court and also other High Courts. 14. Submissions of Smt. Sujatha, learned Additional Government Advocate appearing for the revision petitioner-State in all these petitions ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... meaning assigned in the KST Act; that this provision has been totally misunderstood by the Tribunal by calling in aid entry I, Part M of the Second Schedule to the KST Act wherein also the contents of the entry are similar or identical and with reference to this entry, namely, as it occurs in entry 1(f)(iii)(a) and (iii)(e) of Part M of the Second Schedule reads as machinery (all kinds) and parts and accessories thereof except those fall under other items of same nature and those specified elsewhere and this in combination with sub-entry (iii)(e) of the very entry used in industrial machinery such as twisted drills, grinding wheels, etc., having been made separate entry and going out of the scope of generic entry 1(iiia) and this manner of understanding and interpreting entry 52 of the First Schedule to the Act should be applied. In view of this interpretation in that section 2(B) of the Act is an exercise totally uncalled for. The Schedules in the two enactments are totally different that by process of incorporating or attributing the meaning of sub-entry cannot be created in the Schedule to the Act by a reasoning of this nature to understand the scope of entry 52 of the First Sch ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... h submissions made on behalf of the State-revision petitioner, Smt. Radhika Sriranjani, learned counsel appearing for the assessee, has stoutly defended the case of the respondents. Learned counsel has drawn our attention to the fact that in the wake of the observations made by the Supreme Court enabling the assessee to raise contentions of the nature as to whether the goods in question were consumables. Therefore, whether it can be described as accessories or not being available to the assessee in the wake of the observations of the Supreme Court. In the order of the Supreme Court in the case of the very assessee that was fully demonstrated before the Tribunal and as can be seen from paragraph 28 of the order of the Tribunal, the Tribunal being fully satisfied with the demonstration made before the Bench of the Tribunal by displaying the goods in respect of which tax has been levied, such as drilling bits, cutter, sharp and wild edges and their longevity being very less when put into use and attributable to be answered as consumables and applying the judgment of the honourable Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC), the question is necessarily to be ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... upreme Court were pressed into service and therefore the assessee contended that the goods which the assessee dealt with being in the nature of consumables, it cannot be brought to tax. 22. We have noticed that the question of legality of rectifying the assessment orders for five assessment years in question, is not an issue before us as the Tribunal having affirmed the correctness of the order of rectification and the assessee having not pursued the matter, the subject-matter of revision petition is only the question relating to the taxability or otherwise of the goods of the assessee under the provisions of the Act corresponding to assessment years 2001-02 to 2005-06. 23. We have considered the submissions made at the Bar by Smt. S Sujatha, learned Additional Government Advocate appearing for the petitionerRevenue and Smt. Radhika Shriranjani MD, learned counsel for the respondent-assessee. 24. In our considered opinion, the only aspect which if at all could be examined to determine the tax liability and in respect of the products for the subsequent assessment years is on the aspect of liability in respect of the goods which are in the nature of consumables as the Supreme Cour ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a mistake in this regard in understanding the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) as an authority for the present purpose and for examination of taxability or otherwise of the product, visa-vis, entry 52 of Schedule I of the Act. The taxability of a particular product under a taxing enactment is dependent on the scope of the charging section, subject-matter of charge and the event happening of which attracts the liability for payment of tax. Identification of the person responsible for payment of tax is yet another aspect of a fiscal statute. 30. There are different taxing enactments having different purposes and subjecting to tax different type of goods, events, transactions and the like. The judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) was a case arising in the context of examination of taxability or otherwise of a product and the product therein being described as raw material and as to whether particular tool bits or drilling bits used can be characterized as one within the scope of the phrase "raw material". The question arose in the context of levy of tax under the sales tax ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... dgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) can never be considered as an authority for the purpose of deciding the question as to whether the product is one taxable under entry 52 of the Schedule I to the Act. 36. For the same reason, we also hold that the question as to whether it is a36 consumable or not is of no significance and the fact that the Supreme Court permitted the assessee to raise a contention of this nature, if so advised before the authority will not in any way alter the situation either on fact or in law insofar as the present assessee is concerned, particularly, as the very products were subject-matter of decision of this court and the Supreme Court. The products whether it also fits into description of raw material or a consumable does not make much difference insofar as the present examination is concerned. The Tribunal having heavily relied upon the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC), for reversing the view taken by the lower authorities and going into great detail about the nature of the product and other things and a personal examination of the product which are all i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this decision constitutes an authority for holding that tool bids, cutters, blades used along with other machinery forms part or accessory of the machinery and therefore is taxable under entry 52 of Schedule I to the Act and the products in the case of Addison & Co. Ltd. v. State of Karnataka [2008] 14 VST 182 (Karn) and in the present case being of the like nature, of like use, it should be taken that the taxability of such goods in the hands of the assessee is concluded in terms of the judgment of the Supreme Court. 45. That apart, learned Additional Government Advocate has also contended that the Tribunal has committed an error in placing reliance on the judgments of the Supreme Court to submit that the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) is not an authority for the present purpose; that the Tribunal has gone wrong in assuming that the judgment constituted an authority and also in understanding that the order of this court in the case of Addison & Co. Ltd. [2008] 14 VST 182 (Karn) as well as affirming judgment of the Supreme Court in the case of very assessee may not lay down the correct law as the judgment of the Supreme Court ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ct can be termed as an accessory or component and the test being that without the component the final product being not of any real value makes it as a component and whereas even without a part if the main product of the machinery is functional and can be used and a combination used for other product, makes it an accessory, may be for enhancing the efficiency or performance or even for enhancement of the look and appearance or like. It was held in this case that television antenna is to be held as an accessory of TV set. This decision was, no doubt, rendered in the contest of the provisions of the KST Act and on the question as to whether TV antenna constitutes an accessory and therefore liable to tax or it was a component of a TV set and it cannot be taxed independently. 50. Appearing on behalf of the assessee, Sri K.S. Suryanarayan, learned counsel, has urged several contentions. It is firstly contended that the assessee had claimed the subject goods as consumables and therefore nonscheduled and not taxable; that the assessing officer taking the view that it is a consumable tool and fitting into entry 52 of First Schedule to the Act in itself was not correct and this aberration ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to the Act, etc. 52. In support of this submission, Sri Suryanarayan has placed reliance on the decision of a single Bench of this court in the case of Raja Motors v. Additional Deputy Commissioner of Entry Taxes-Cum-Commercial Taxes, Assessments-III, Bangalore City [1997] 106 STC 309 (Karn); [1997] 42 KAR LJ 57. Reliance is also placed on the judgment of this court in the case of Kennametal Widia India Ltd. v. State of Karnataka [2010] 69 KAR LJ 284 to urge that small machine tools manufactured and sold to another dealer for use as component and raw material are consumable to manufacture of other goods and recognizing this position, a notification has been issued under section 8A of the KST Act providing for concessional rate of tax, etc. This judgment is called in aid to submit that raw material or consumables are treated differently from parts and accessories thereof. 53. One another main argument urged on behalf of the assessee is that the test for taxability of a goods under the provisions of the Act is what the goods is at the point of entry into local area and subsequent manner of use or application of the goods is of no significance and therefore it is submitted that assu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... are arguments sought to be urged before the court for the first time without any basis and it is not even proper on the part of the assessee to call in such arguments and supporting decisions and examination cannot be go beyond the taxability under entry 52 of the First Schedule to the Act in the context of the facts of the case and in the light of the judgment of the Supreme Court in the case of Addison & Co. Ltd. [2009] 23 VST 5 (SC). 57. Even otherwise, we find the argument of interpreting or understanding the scope of entry 52 of the First Schedule to the Act by referential legislation fails on many counts. First of all, it is to be borne in mind that the understanding of a word or expression in the Act is not the same as interpreting a word or phrase which is used in a particular context in a different enactment, even when the words and expressions not specifically defined or sought to be understood in the context of definition given to such words and expressions in an analogous enactment, it cannot be totally taken out of context and it can only be in the context. 58. Scope of entry 52 of the First Schedule to the Act cannot, in our understanding, be understood or explaine ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nding the purpose or even words occurring in a different fiscal enactment. Mere fact that octroi was a tax at the entry point and levy of tax under the provisions of the Act is also only after entry of the goods into the local area in itself cannot be a conclusive factor to understand the scope of chargeability under the provisions of the Uttar Pradesh Nagar Mahapalika Adhiniyam, 1959 and its Rules and Regulations should be assigned in understanding the provisions of the present Act. 63. Yet another reason why the judgments of this nature cannot constitute an authority is that examination by courts was provisions of different enactments and if it is an examination by the Supreme Court and a decision is rendered in the context of a particular statutory provisions in an enactment, the judgment can constitute a law declared by the Supreme Court within the meaning of article 141 of the Constitution of India, only with reference to that particular provisions under the particular enactment and is not a law declared vis-a-vis any other statutory provisions. This position combined with the fact that in taxing statutes, examination being with reference to a particular product and a particu ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ean being a part or accessory. It is, therefore, we reject the argument that mere fact that the goods/products of the assessee can happen to be a consumable by itself cannot take it out of the taxability under entry 52 of the First Schedule to the Act, as even otherwise it is a part or accessory to a machinery. 67. Though Sri Suryanarayan, learned counsel for the assessee, has urged that the assessing officer had described the product as a consumable tool, but that by itself does not absolve the assessee of the liability, as the assessee's effort rested with an attempt to show that the tool is consumable and therefore within the scope of entry 52 of the First Schedule to the Act. A tool in a given situation can also be part, and otherwise it can even be an accessory. It may be one consumed in the course of the application of the tool with the machinery or become useless over a period after use. These are all, in our considered opinion, not a determinative test for holding that it is not a part or an accessory. 68. There is no denial in all these cases that the particular product with which the assessee is dealing is one which has been used in combination with other machinery ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n affirmed in the appeal by the first appellate authority, the assessee was before the Tribunal questioning the correctness of these orders. Tribunal having taken the view that these products are goods brought into the local area by the assessee being in the nature of consumables and therefore not taxable as parts or accessories on the authority of the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC), the State is in revision to get over the orders of the Tribunal. 72. The grounds in support of these revision petitions are the same as in the above revision petitions which we have disposed of and therefore arguments on behalf of the State-revision petitioner by Ms. S. Sujatha, learned Additional Government Advocate are the same. It is submitted by the learned Government Advocate the very arguments as are urged in the above cases equally hold good for the present revision petitions also. 73. We also notice that the Tribunal had rendered its decision which is subject-matter of CRP No. 235 of 2010 and 289 of 2010 on January 18, 2010 and by purporting to follow and apply the ratio of the judgment of the Supreme Court in the case of Rewa Coal Fields ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o the local area and examination as to what is the goods brought at the entry point of local area and not the manner of use of the goods later and as to whether it can be used in combination with some other machinery to become an accessory to some other machinery or even if it can be used as part of some other machinery at a later point of time after getting the goods into the local area. 76. Sri Rabhinathan has also placed reliance on the judgment of this court in the case of K.B. Dani v. State of Karnataka [1979] 44 STC 276 (Karn), where this court had occasion to examine the question as to a trailer is part or accessory of a tractor and having opined that a tractor is in the nature of an agricultural machinery and that contention that tractor trailer is not in the nature of machinery was not taxable within the scope of entry 20 of the Second Schedule to the KST Act and on the same analogue, cutting tools brought into local area by the assessee being just used by propelling or applying a circular motion by using an independent machine cannot be called as either part or accessory to a machine which propels or renders circular motion to the tool and therefore it has to be taken ou ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... btedly and readily accepted, it is not attracted to the present situation and is not at all applicable. A purposive interpretation is given for effectuating some words and phrases expressly mentioned and provisions made for a particular purpose. The manner of under standing section 2(B) of the Act is only for the purpose of filling the gap or a vacuum in understanding any of the phrase or expression used in this enactment. Understanding of the scope of entry is not one such situation. It is, therefore, the argument that by giving a purposive interpretation to section 2(B) of the Act one should travel to the provisions of the KST Act and look into the scope and manner of entry 1(iii)(e) of Part M of the Second Schedule to the KST Act to be outside the scope of entry 1(iii)(a) of the same part and therefore a meaning of this nature should be attributed for understanding entry 52 of Schedule I to the Act does not stand to reason, as by carving out a separate entry in the Schedule to the KST Act, the scope of entry 1(iii)(a) of Part M is reduced. It is not so in the case of entry 52. For this reason also, the argument fails. In fact, there is no corresponding entry in the present enact ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er, there is no charge. The fact of the notified goods coming into local area and the purpose for which it is brought are both significant and it is a combined operation of the two, which completes the charges in respect of the specified goods. Therefore, assuming that use, application or consumption, etc., takes places not at the entry point but later cannot make any difference to the charge so long as the purpose for which the goods have been brought into the local area is for one of the three enumerated purposes such as use, consumption or sale by the dealer which manner of application of goods may occur later. 84. It is, therefore, we accept the arguments of learned Government Advocate and rejected the arguments of the learned counsel for the assessee. Therefore these revision petitions are also allowed, orders of the Tribunal set aside by answering the question accordingly and the orders passed by the assessing officer, affirmed by the first appellate authority, are restored. In CRP No. 147 of 2011: 85. This revision petition is also by the Revenue and directed against the order dated August 2, 2010, passed by the Tribunal in STA No. 1481 of 2009. Under the impugned order, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... meaning of the word "component part" of machinery and had opined that the needles used in a gramophone for the purpose of playing a record is not component part of a gramophone and therefore submitted that the view taken by the assessing authority and affirmed by the appellate authority that the products are component parts of the cutting machineries in combination with which the subject goods are used cannot form part of the cutting machinery or tool cutting machinery and therefore submits that the view of the Tribunal should be affirmed. 91. An alternative argument is also addressed by Sri Keshavamurthy, learned counsel for the assessee, to submit that the assessee being new industrial unit has enjoyed certain benefits during its early stages; that the industry had a general exemption for a period of three years from the date of its setting up and which ended by March 31, 2004 and thereafter the assessee has been given exemption in terms of notification No. FD.161.CET.2001[1] dated November 30, 2001 read with certificate executed by the Industries Department bearing No. DIC/CTA/ ETE/C1/ 2004-05 dated April 8, 2004 and therefore also the assessee cannot be subjected to ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o raw materials, component parts, semi-finished goods, etc., and entry itself is different and therefore the benefit under the second notification cannot be sought to be availed of in respect of items or goods covered under entry 52 and with reference to which perhaps the first notification was issued. 96. We have bestowed our attention to the rival submissions and insofar as the judgment of the Tribunal purporting to follow the judgment of the Supreme Court in the case of Rewa Coal Fields [2002] 125 STC 212 (SC) is concerned, we have already elaborately discussed the issue and opined on the same in the other revision petitions preferred by the State as mentioned earlier. 97. Insofar as reliance placed on the judgment of the Allahabad High Court in the case of Punjab Gramophone House [1979] 43 STC 141 is concerned, the judgment was particularly in the context of examination undertaken by the court under the provisions of section 3A of the U. P. Sales Tax Act, 1948 and as to whether the particular item fitted into entry No. 7 under a particular notification issued under the provisions of that Act and with the specific description "gramophones and component parts thereof and r ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... LJ 150 was in the context of examining the scope of entry 7 as it stood then reading as "Industrial machineries and parts and accessories thereof'. 104. It is of significance to notice that parts and accessories are only such parts and accessories to the main description in the entry, namely, "industrial machinery". 105. We notice the corresponding present entry is entry 52 and reads as "machinery of all kinds and parts and accessories thereof", but excluding agricultural machinery. If machinery is not an industrial machinery, parts and accessories thereof also does not arise. Entry 7 while covered only parts and accessories of industrial machinery, the present entry covers parts and accessories of all kinds of machinery excluding agricultural machinery. Therefore, the meaning of the words "parts and accessories" also has to be understood in a generic context and the test has to be as to whether the parts and accessories are a part and accessory of any type of machinery in general and in particular with the type of machinery with which the dealer causes entry for any of the purposes mentioned in the charging section. 106. Obviously, a part ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s reliance placed on the notification is concerned and even as submitted by learned Additional Government Advocate, an exemption notification issued with reference to entry 80 cannot be employed for claiming exemption under the levy of tax with reference to goods in entry 52 and it is well known exemption notifications should be construed strictly and scope of the exemption notification cannot be enlarged either by way of analogy or logic. It operates only in respect of the specific goods mentioned and not beyond. Therefore, the argument that the assessee can even otherwise claim exemption from levy of tax with reference to second exemption notification cannot be accepted. Such being the finding of the Tribunal, we do not find anything wrong in the order. 112. Therefore, this revision petition is allowed answering the question accordingly. RE: CRP No. 292 of 2010 and CRP Nos. 308-309 of 2010 connected with CRP NO. 165 of 2011 and 166-167 of 2011: 113. State is the revision petitioner in these petitions preferred under section 15A of the Act. The respondent-assessee is a limited company, manufacturer and trader of drill bits, cutters and reamers amongst others. The assessment yea ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ntended that it is not taxable. This argument having found favour before the Tribunal, the present revision petitions before us by the State. 117. It is also the submission of Mr. Gurudatta Shenoy, learned counsel for the assessee that the assessee has its manufacturing unit at Nasik and these goods are brought into local area where it has received the goods on stock transfer basis to its branch at Bangalore and placing reliance on the decision of this court in the case of Mysore Industrial Supplies [1997] 106 STC 585 (Karn); [1997] 42 KLJ 150, his submission is that the goods are not brought into local area as parts or accessories of any machinery at the point of entry and therefore, he is not liable to pay tax under entry 52 of the First Schedule to the Act. Mr. Shenoy has also pointed out that there are certain anomalies in the orders of the assessing authority and the first appellate authority that the assessing authority in one part of the order has opined that the goods are in the nature of components whereas in the very order, it has also opined that the goods are accessories. Therefore submits that it cannot be both at the same time. Particularly exclusive of one another a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... owing or otherwise as a discounts or as deduction is based on fact and not on principle of law. Basically, it is on fact and if it enables the provision, it may be so claimed as deduction and not otherwise. Therefore, we do not propose to examine further the merits of these contentions urged in these revision petitions. 121. In fact, Smt Sujatha, learned Additional Government Advocate, joins issue and the main argument sought to put forth before this court in the revision petitions preferred by the State to the extent the matter was in issue earlier is, if the order of the Tribunal does not mention that one way or the other, the assessee having succeeded, his arguments can be called in aid only to that extent, we examine the submission made on behalf of the assessee. 122. Insofar as reliance placed on the decision of this court in Subhash Marketing's case [2000] 118 STC 136 (Karn) is concerned, we have already clarified that the circular issued in the context of the KST Act and clarified certain position cannot have any bearing and binding nature in respect of the provisions of the present Act. Clarification and withdrawal of the earlier clarification both having taken place ..... X X X X Extracts X X X X X X X X Extracts X X X X
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