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Issues: Whether the spare parts of tractors could be classified as luxury goods under the heading "spare parts of motor vehicles" under the Punjab General Sales Tax Act.
Analysis: The tractor was treated as a distinct item and was not regarded as a motor vehicle within the relevant sales tax classification. The notification itself showed separate treatment of tractors, including a fixed tax incidence, which indicated that tractors were not intended to be treated as luxury goods. On that basis, spare parts of tractors also could not be brought within the category of luxury goods as spare parts of motor vehicles.
Conclusion: The spare parts of tractors are not luxury goods under the Punjab General Sales Tax Act and are not classifiable as spare parts of motor vehicles.