Strict construction of motor-vehicle tax entry led to fuel injection equipment being treated as diesel-engine machinery, not a vehicle component.

Fuel injection equipment was treated as an integral and necessary part of a diesel engine, with no independent utility in a motor vehicle unless attached to the engine. On that reasoning, it was not classified as a spare or component part of a motor vehicle merely because diesel engines may be fitted in vehicles. The taxing entry for motor-vehicle component parts was construed strictly, and any doubt was resolved in favour of the assessee. The stated result was classification at 6% rather than 10%, with the assessment treating the equipment as a motor-vehicle component set aside.

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Issues: Whether fuel injection equipment is taxable as a component part of a motor vehicle at 10% or as a part of diesel-engine machinery at 6%.

Analysis: The fuel injection equipment was found to be an integral and necessary part of a diesel engine, with no independent use or utility in a motor vehicle without attachment to the engine. It was therefore not treated as a spare part of a motor vehicle merely because diesel engines may be fitted in vehicles. The taxing entry dealing with motor-vehicle component parts was construed strictly, and where doubt existed the interpretation favouring the assessee was preferred.

Conclusion: The fuel injection equipment was held taxable at 6% and not at 10%, and the assessment treating it as a motor-vehicle component was set aside.

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