Truck body classification as motor vehicle component parts brought sales under the special tax rate.

Prepared truck bodies were held to be integral component parts of motor vehicles because a motor vehicle, in its ordinary commercial sense, does not ordinarily function as a conveyance without a mounted body. The body fitted to the chassis was therefore treated as necessary to the constitution and use of the vehicle, bringing the sale within the notification under section 3-A of the U.P. Sales Tax Act rather than within the residuary classification of unclassified goods under section 3. The reference was answered in favour of the Revenue, and the special tax rate applied to truck bodies sold by the assessee.

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Issues: Whether the sale of prepared truck bodies was liable to tax as component parts of motor vehicles under the notification issued under section 3-A of the U.P. Sales Tax Act, or as unclassified goods under section 3.

Analysis: A motor vehicle, in its ordinary and commercial sense, is a conveyance intended to carry passengers or goods. A component part is an integral constituent necessary to the constitution and functioning of the whole article. A motor and chassis on wheels do not constitute a complete motor vehicle unless fitted with a suitable body; the body is necessary for the vehicle to serve its ordinary purpose. The body mounted on the chassis is therefore an integral part of the motor vehicle and falls within the expression "component parts of motor vehicles" in the notification.

Conclusion: The prepared truck bodies were rightly treated as component parts of motor vehicles and were chargeable under section 3-A of the U.P. Sales Tax Act. The decision is against the assessee and in favour of the Revenue.

Final Conclusion: The reference was answered by holding that truck bodies sold by the assessee fall within the notified category of component parts of motor vehicles and are taxable at the special rate.

Ratio Decidendi: Where a motor vehicle cannot ordinarily function as a conveyance without a mounted body, the body forms an integral component part of the vehicle for purposes of sales tax classification.

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