Component parts of motor vehicles: bus bodies mounted on chassis attract the lower tax rate under the relevant schedule entry.

Bus bodies mounted on motor chassis are treated as component parts of motor vehicles, not as mere accessories or separate spare parts. On that characterisation, the lower tax rate under Entry 9 of Schedule A applies rather than the higher rate, and departmental instructions or an assessment adopting the higher rate cannot override that settled classification. The legal position is applied to the relevant assessment year, with bus bodies mounted on chassis taxed at 6% as component parts of motor vehicles.

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Issues: Whether bus bodies mounted on motor chassis are component parts of motor vehicles and, if so, whether they are exigible to tax at 6% under Entry 9 of Schedule A rather than at 10%.

Analysis: The legal position was treated as settled by earlier authority that bus bodies mounted on motor chassis are not mere accessories or spare parts but form component parts of motor vehicles. On that basis, the applicable entry was the one prescribing the lower rate for such goods, and the departmental instructions and the assessment adopting the higher rate could not prevail over that classification. The court accordingly applied the settled characterisation of bus bodies to the present assessment year and rate dispute.

Conclusion: Bus bodies mounted on motor chassis are component parts of motor vehicles and are taxable at 6% under Entry 9 of Schedule A; the answer was therefore in favour of the dealer and against the Revenue.

Final Conclusion: The reference was decided by holding that the lower rate of tax applied to bus bodies as component parts of motor vehicles.

Ratio Decidendi: Where bus bodies are mounted on motor chassis, they constitute component parts of the motor vehicle and must be taxed according to the entry applicable to such component parts, not as separate items at the higher rate.

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