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Issues: Whether bus bodies are components of motor vehicles for the purpose of the sales tax notification, and whether the Tribunal was justified in refusing to state a case on that question.
Analysis: The notification under Section 5 of the Orissa Sales Tax Act, 1947 treated motor vehicles, including chassis, spare parts and components of motor vehicles, as taxable at the specified rate. The term "component" was not defined, so its common parlance meaning was applied. A bus body fitted on a chassis makes a bus, and therefore forms part of the motor vehicle. On that interpretation, the entry covering components of motor vehicles applied from 1 May 1976, while for the earlier period the residuary entry governed. Since the question posed by the assessee was answered by the existing record and no further factual inquiry was necessary, no referable question of law survived.
Conclusion: Bus body was held to be a component of a motor vehicle, and the Tribunal was in refusing to state a case.
Final Conclusion: The application seeking reference failed, and the assessee's challenge to the tax treatment did not succeed.
Ratio Decidendi: Where the statutory term is undefined, it must be construed in its common parlance sense, and a bus body fitted on a chassis is a component of the motor vehicle for the purpose of the relevant tax entry.