ORDER

1. We have read the principal judgment under appeal (which is reported in Rajasthan SEB v. State of Rajasthan ((1980) 45 STC 201 (Raj)). We are of the view that the High Court was entirely right in the view that it took.

2. The High Court held that trucks, trolleys, trailers and the like, but not passenger vehicles, as also their accessories and spare parts, tyres and tubes a could be purchased by the respondent Board at the concessional rate of tax prescribed under Section 8(1) of the Central Sales Tax Act, 1956, and that, to make things clear, the respondent Board was entitled to have its registration certificate altered to include "tools and plants, including vehicles and other transportable goods, including their spare parts, tubes and tyres". The respondent Board is engaged in the business of generation and distribution of electricity. What is used in the distribution of electricity or intended for such use falls within the scope of Section 8(3) (b) read with Rule 13 of the Central Sales Tax (Registration and Turnover) Rules, 1957.

3. Insofar as soaps, paints and varnishes are concerned, the High Court rightly upheld the finding of the Board of Revenue that they were permissible only insofar as they were intended to be used for the purpose of cleaning boilers and machinery and other equipment and for the purpose of painting machinery and electrical goods. Raincoats could be purchased at the concessional rate of tax so far as they were necessary for the use of linesmen working on transmission lines during the rainy season and winter; similarly, battery cells to the extent they were necessary for use by linesmen for working on transmission lines during the night.

4. The learned counsel for the appellant State drew our attention to the judgment of this Court in J. K. Cotton Spg. & Wvg. Mills Co. Ltd. v. STO ((1965) 2 SCR 900 : AIR 1965 SC 1310 : (1965) 16 STC 563). We do not find anything in that judgment that runs counter to the view taken by the High Court. It was held in $K. Cotton Spg. & Wvg. Mills case ((1965) 2 SCR 900 : AIR 1965 SC 1310 : (1965) 16 STC 563) that if a process or activity was so integrally related to the ultimate manufacture of goods so that without that process or activity manufacture may, even if theoretically possible, be commercially inexpedient, goods intended for use in the process or activity as specified in Rule 13 would qualify for special treatment. The motor vehicles aforementioned and soap, paints, raincoats and battery cells, to the extent aforementioned, are integrally related to the distribution of electricity and their non-use would make distribution commercially inexpedient. In Travancore Tea Estates Co. Ltd. v. State of Kerala ((1976) 4 SCC 470 : 1977 SCC (Tax) 33 : (1977) 1 SCR 755), what was in issue was the use of fertilizers in the manufacture of tea. This Court distinguished between the agricultural process of cultivation of tea and the subsequent manufacture or processing thereof to make it drinkable and held that the use of fertilizers was necessary only for the process of cultivation which ended with the harvest of the tea leaves. The judgment in Tata Engineering and Locomotive Co. Ltd. v. State of Biha ((1994) 6 SCC 479) dealt with a notification that used language substantially different from that with which we are concerned and the judgment, therefore, is of no assistance to the case of the appellant.

5. The appeals are dismissed, with no order as to costs.