Sales tax classification of chassis with engine turns on common trade meaning, not Motor Vehicles Act definitions.

For sales tax classification, a chassis fitted with an engine was held to remain a chassis of a motor vehicle until a body is built on it. The expression "motor vehicle" in the notification was interpreted in its common or trade sense, not by importing the definition from the Motor Vehicles Act. Applying that approach, the goods did not qualify as a light commercial vehicle and were taxable under the entry for chassis of motor vehicles. The revenue classification was upheld and the challenge to the lower-rate assessment failed.

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Issues: Whether chassis sold along with engine could be treated as a light commercial vehicle under the tax notification or was taxable as chassis of motor vehicle.

Analysis: The notification granted different reduced rates for chassis of motor vehicles and for motor vehicles of the category of light commercial vehicles. The expression "motor vehicle" in the sales tax context was held to bear its common parlance or trade meaning, not the definition in the Motor Vehicles Act. On the facts, what was sold was chassis with engine, without a body built on it. Applying the ordinary commercial understanding and the reasoning of prior decisions, a chassis with engine does not become a motor vehicle for sales tax purposes until a body is built upon it. It therefore fell within the entry relating to chassis and not within the entry for light commercial vehicles.

Conclusion: The assessee was not entitled to assessment at the lower rate applicable to light commercial vehicles; the goods were taxable as chassis of motor vehicles, and the revision failed.

Final Conclusion: The classification adopted by the revenue authorities was upheld and the assessee's challenge to the levy was rejected.

Ratio Decidendi: For sales tax purposes, a chassis fitted with an engine remains a chassis of motor vehicle unless and until a body is built on it; the statutory expression must be understood in its common or trade sense rather than by borrowing the definition from the Motor Vehicles Act.

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