Embedded preparation and installation charges form part of sale price; motor vehicle number plates are not accessories for special-rate tax.

For sales tax purposes, embedded wages for preparing number plates and traffic signals, as well as installation costs included in a flat sale price, could not be deducted from taxable turnover because Section 2(h) treated sums charged for work done in respect of the goods at or before delivery as part of the sale price. Number plates for motor vehicles were also held not to be accessories, since they were not essential equipment connected to the vehicle's engine, transmission or body and served a regulatory identification function. They therefore did not qualify for the special rate under entry I(iii) of Schedule I and were taxable only at the general rate.

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Issues: (i) Whether the wages paid for preparing number plates and traffic signals, and the cost of installing traffic signals, could be excluded from the sale price while computing taxable turnover. (ii) Whether number plates for motor vehicles were accessories of motor vehicles chargeable at the special rate under entry I(iii) of Schedule I of the Sales Tax Act.

Issue (i): Whether the wages paid for preparing number plates and traffic signals, and the cost of installing traffic signals, could be excluded from the sale price while computing taxable turnover.

Analysis: The term "sale price" in Section 2(h) of the Sales Tax Act includes sums charged for anything done by the dealer in respect of the goods at or before delivery. The charges for preparing the plates and signals were included in the flat sale price and were not separately shown. The installation cost also was not separately charged as installation charges.

Conclusion: The deduction was not permissible and the claim failed.

Issue (ii): Whether number plates for motor vehicles were accessories of motor vehicles chargeable at the special rate under entry I(iii) of Schedule I of the Sales Tax Act.

Analysis: Number plates were held not to be essential equipment of a motor vehicle and had no connection with its engine, transmission, or body. They were required under Section 28 of the Motor Vehicles Act for registration purposes and could ordinarily serve as plates for other vehicles as well. On that reasoning, they did not fall within the concept of accessories in entry I(iii) of Schedule I.

Conclusion: Number plates were not accessories and were chargeable only at the general rate, not the special rate.

Final Conclusion: The assessment was reduced by excluding the special-rate treatment for number plates, while the claim for deduction of wages and installation cost was rejected, resulting in a partial relief to the applicants.

Ratio Decidendi: For sales tax purposes, a flat sale price that includes preparation or installation charges cannot be reduced by those embedded costs, and articles that are not an essential part of a motor vehicle and are used for identification or regulatory purposes do not constitute motor vehicle accessories for special-rate classification.

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