VEERASWAMI, C.J.

In these two tax cases, the question presented is whether spray booths, dust collectors and textile humidification plants are air-conditioners within the meaning of entry 4 of the First Schedule to the Madras General Sales Tax Act, 1959. That entry is : Refrigerators, air-conditioning plants, component parts of refrigerators or air-conditioning plants. On such goods, the rate of tax levied on their sales is 12 per cent., and the levy is at the point of first sale in the State. The Tribunal has held that these articles are not within the purview of the entry.

In respect of the first two, namely, spray booths and dust collectors, we are clearly of opinion that they are not air-conditioners. The spray booth is intended for component painting in the engineering industry. The spray booth comprises of a collecting section and a booth section. The former may be used separately as a paint-mist collector in a spray shop or in combination with one or two booth sections in sequence. The paint-mist collector uses a closed-cycle water system, a suitable paint neutraliser being added. From a channel at the top of the booth, the water runs in an even film down the scree