Motor vehicle accessories test: trailers attached to jeeps were not treated as taxable accessories under the relevant entry.

Trailers attached to jeeps were considered under the sales tax entry for motor vehicle accessories, spare parts and component parts. The Court held that the meaning of "accessories" depends on the statutory context and may be wide, but it gave decisive weight to the Commissioner's circular of 18 June 1979 stating that a trailer was not an accessory to a jeep. As the appellate authorities had relied on that circular to maintain uniform assessment treatment, the revision order was not disturbed and the revisions failed.

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Issues: Whether trailers attached to jeeps were taxable as accessories of motor vehicles or as unclassified items.

Analysis: The relevant entry covered motor tyres and tubes, spare parts and component parts, as well as articles adapted for use as accessories of motor vehicles. The meaning of "accessories" had to be gathered from the context of the entry, and the Court noted that the expression may have a wide meaning depending on the statutory setting. The Court gave decisive weight to the Commissioner's circular dated 18 June 1979, which had taken the view that a trailer was not an accessory to a jeep and had been relied upon by the appellate authorities to maintain uniform treatment for the assessment years in question. In revision, the Court found no reason to disturb the appellate order based on that circular.

Conclusion: The trailers were not interfered with as taxable accessories of jeeps, and the revisions failed.

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