Common parlance meaning of road transport vehicle excludes a tractor, preserving investment allowance under section 32A.

The expression "road transport vehicles" in section 32A of the Income-tax Act, 1961 was construed in its common parlance sense because the Act did not define it. On that footing, the term covers vehicles ordinarily used for transporting goods or passengers on roads, not agricultural machinery. A tractor remains primarily a tilling implement and does not become a road transport vehicle merely because it may carry persons or be fitted with a trolley. The assessee was therefore entitled to investment allowance, and the tractor did not fall within the exclusion for road transport vehicles.

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Issues: Whether a tractor used for hire with a trolley is a road transport vehicle so as to deny investment allowance under section 32A of the Income-tax Act, 1961.

Analysis: The expression "road transport vehicles" is not defined in the Income-tax Act, 1961 and was therefore construed in its common parlance sense. On that approach, such vehicles are those ordinarily used for transporting goods or passengers on roads. A tractor is primarily agricultural machinery for tilling land and does not become a road transport vehicle merely because it can sometimes be used to carry persons or be fitted with a trolley. The statutory context supported adoption of the popular and commonsense meaning rather than a broader technical meaning.

Conclusion: A tractor is not a road transport vehicle, and the assessee was entitled to investment allowance under section 32A of the Income-tax Act, 1961.

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