Single sale of finished vehicle governs taxation; chassis and body were not separate taxable transactions.

Where the contractual arrangement and invoices showed supply of a completed station wagon or autorickshaw, the transaction was treated as a single sale of the finished vehicle rather than separate sales of chassis and body. The fact that tax had been shown on the body-building component did not change the taxable event, because the commercial substance was supply of the completed vehicle under one arrangement. Accordingly, prior tax on the body did not exclude tax on the finished vehicle under Schedule I item 3 of the Tamil Nadu General Sales Tax Act, and the assessment on the finished vehicles was upheld.

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Issues: Whether the body built on a chassis, where the finished vehicle was contracted to be supplied as a station wagon or autorickshaw, could be treated as a separate taxable transaction, and whether prior tax on the body excluded tax on the finished vehicle under Schedule I item 3 of the Tamil Nadu General Sales Tax Act.

Analysis: The invoices and surrounding circumstances showed that the customers ordered finished station wagons or autorickshaws, not a chassis and body as independent goods. The chassis allocation, body building charges, and later delivery were all part of the same commercial arrangement for supply of the completed vehicle. The prior tax shown on the body building component did not alter the nature of the transaction, because the taxable event was the sale of the finished vehicle and not two distinct sales of chassis and body.

Conclusion: The sale was of the finished vehicle as a single transaction, and the body was not separately taxable in the manner contended by the assessee.

Final Conclusion: The tax revision cases failed, and the assessment of tax on the finished station wagons and autorickshaws was upheld.

Ratio Decidendi: Where the contractual and factual arrangement shows supply of a completed vehicle, the transaction is to be treated as a single sale of the finished goods and not as separate sales of chassis and body.

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