Commercial sense governs vehicle classification; chassis without body is not a motor vehicle, and resale cannot be split for tax.

In a taxing statute, goods are classified in their common commercial sense rather than by artificial splitting. A truck-plus-chassis-frame fitted with engine and wheels but without a body was treated as a chassis, not a motor vehicle, because the Act separately referred to motor vehicles, chassis, and bodies built on chassis. On resale of a completed vehicle after body-building, the sale could not be bifurcated into chassis and body components; the transaction was taxable as a single integrated vehicle, and no deduction of chassis value was permitted absent an express statutory set-off.

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Issues: (i) Whether a truck-plus-chassis-frame fitted with engine and wheels, but without a body, is a "motor vehicle" or only a "chassis" for the purposes of the Karnataka Sales Tax Act, 1957. (ii) Whether, on resale of an old vehicle after body-building, sales tax can be confined only to the body value by bifurcating the transaction.

Issue (i): Whether a truck-plus-chassis-frame fitted with engine and wheels, but without a body, is a "motor vehicle" or only a "chassis" for the purposes of the Karnataka Sales Tax Act, 1957.

Analysis: The relevant entries in the Second Schedule distinguished between "motor vehicles", "chassis of motor vehicles" and "bodies built on motor vehicle chassis". The expression had to be understood in its popular and commercial sense, as used by persons conversant with the subject-matter. Applying that test, a mere chassis-frame fitted with engine was only an incomplete vehicle and not an article used as a means of conveying passengers or goods. The scheme of the Act and the separate treatment of chassis and bodies also showed that the legislature did not treat the chassis-frame itself as a motor vehicle.

Conclusion: The truck-plus-chassis-frame was not a motor vehicle; it was a chassis falling under the relevant entry for chassis of motor vehicles.

Issue (ii): Whether, on resale of an old vehicle after body-building, sales tax can be confined only to the body value by bifurcating the transaction.

Analysis: The court held that there was no warrant in the statute for splitting the sale of the completed vehicle into separate sales of chassis and body. The Act contained no crediting or deduction mechanism comparable to other specific provisions where tax already paid on an input was given set-off. Equity could not be used to read such an exception into the taxing entry. The commercial reality was that the buyer purchased a single integrated vehicle, not two separately taxable articles.

Conclusion: The resale of the completed vehicle was liable to tax as a whole, and no deduction of the chassis value was permissible by bifurcation.

Final Conclusion: The Karnataka High Court construed the taxing entries in their ordinary commercial sense and upheld tax on the resale of the completed vehicle without permitting a chassis-body split, resulting in relief to the Revenue and rejection of the assessee's contrary claim.

Ratio Decidendi: In a taxing statute, the description of goods must be construed in common parlance and commercial sense, and a chassis-frame without a body is not a motor vehicle unless the statute expressly provides otherwise.

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