Motor vehicle spare parts classification turns on whether goods are true replacement parts, not general-use component parts.

Pins, nuts, bolts, levers and black-plates were held not to fall within item No. 78 covering spare parts and accessories of all types of motor vehicles. The entry was read as limited to goods meant exclusively for motor vehicles, not articles of general use capable of application in different machinery or equipment. The text distinguishes a "spare part" as an extra part kept for emergency replacement from a mere component part used in making other parts. On that basis, the goods manufactured by the assessee were treated as component parts, not motor vehicle spare parts or accessories, and were therefore outside the concessional tax entry.

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Issues: Whether pins, nuts, bolts, levers and black-plates manufactured and sold by the assessee were 'spare parts and accessories of all types of motor vehicles' under item No. 78 of the relevant notification and therefore taxable at 12 per cent.

Analysis: Item No. 78 covered tyres, tubes, spare parts and accessories of all types of motor vehicles excluding those meant for tractors. Reading the entry with other entries using similar expressions showed that the expression was intended to apply exclusively to motor vehicles and not to general machinery, equipment or instruments. The articles in question were of common use and could be utilised in several kinds of machinery. Judicial interpretation of the expression 'spare part' treated it as an extra part kept for emergency replacement, and distinguished it from a mere component part. The items manufactured by the assessee were component parts used in making other parts and could not be treated as spare parts or accessories of motor vehicles.

Conclusion: The items did not fall under item No. 78 and were not taxable as spare parts or accessories of motor vehicles at 12 per cent.

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