Legislative amendment as interpretive aid showed customer-supplied chassis bodies were outside the pre-amendment sales tax entry.

Ambiguous sales tax entries may be interpreted with the aid of later legislative amendment and contemporaneous administrative understanding. On that approach, bodies built on chassis supplied by customers were not covered by item 3 of Schedule I to the Tamil Nadu General Sales Tax Act, 1959 before the 1965 amendment, because the later insertion of bodies built on chassis belonging to others indicated that the earlier wording did not clearly include them. The interpretive history showed that the amendment was intended to bring such bodies within the entry, so the disputed turnover could not be taxed under the pre-amendment provision.

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Issues: Whether bodies built on chassis supplied by customers were taxable under item 3 of Schedule I to the Tamil Nadu General Sales Tax Act, 1959 prior to its amendment in 1965.

Analysis: The disputed turnover related to body-building on chassis supplied by customers. The question was whether such bodies could be treated, before the 1965 amendment, as articles adapted for use as parts or accessories of motor vehicles under item 3 of Schedule I. The amendment made in 1965 specifically inserted bodies built on chassis of motor vehicles belonging to others, which showed that the prior entry did not clearly cover them. The statement of objects and reasons indicated that such bodies had been taxed differently and that the amendment was intended to bring them within item 3. The Court treated this legislative history and the Government's own understanding as a relevant guide to the correct interpretation of the earlier entry.

Conclusion: Bodies built on chassis supplied by customers were not attracted by item 3 of Schedule I before its amendment in 1965.

Final Conclusion: The assessment on the disputed turnover could not be sustained and the tax case was allowed.

Ratio Decidendi: Where a statutory entry is ambiguous, the legislature's subsequent amendment and the contemporaneous administrative understanding may be used as an interpretive guide to determine that the pre-amendment entry did not cover the disputed goods.

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