Tractor parts classification: tyres and tubes are integral components, so the lower VAT rate applies.

Tyres and tubes of tractors are treated as parts of tractors where the statute does not define "parts" and the term is given its ordinary meaning. The reasoning is that a tractor is incomplete for its intended function without tyres and tubes, because they are necessary for mobility and effective use, and the expression "parts thereof" covers constituent components essential to the working of the whole. On that basis, tyres and tubes of tractors fall under serial No. 84 of Part I of Schedule C of the West Bengal Value Added Tax Act, 2003 and are taxable at the lower rate, while the higher rate under Schedule CA does not apply.

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Issues: Whether tyres and tubes of tractors are "parts" of tractors and therefore taxable at 4% under serial No. 84 of Part I of Schedule C of the West Bengal Value Added Tax Act, 2003, or fall under Schedule CA and attract tax at 12.5%.

Analysis: The expression "parts" was not defined in the Act, so the ordinary meaning of the term was applied. The reasoning treated a tractor as incomplete for its intended function without tyres and tubes, since these are necessary for mobility and effective use. The discussion drew support from authorities distinguishing integral parts from accessories and spare parts, and from the principle that the wider expression "parts thereof" includes constituent portions essential to the working of the whole. On that basis, tyres and tubes of tractors were regarded as integral components of tractors rather than separately taxable items under the higher-rate schedule.

Conclusion: Tyres and tubes of tractors are parts of tractors and fall within serial No. 84 of Part I of Schedule C of the West Bengal Value Added Tax Act, 2003. The higher tax rate under Schedule CA does not apply.

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