Fuel-efficiency certificate requirement governs concessional duty for body-built motor vehicles; supplier's certificate is not enough.

Notification No. 462/1986-CE granted concessional duty only to fuel-efficient light commercial motor vehicles meeting the prescribed fuel-efficiency test and certification requirements issued by the competent authority and designated Government officer. Body building on a duty-paid chassis constituted manufacture of motor vehicles, so the appellant was treated as a manufacturer, but that status did not by itself satisfy the exemption conditions. The appellant did not hold the required certificate, and a certificate held by the chassis supplier could not be treated as compliance with the notification. The concessional rate of duty was therefore unavailable.

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Issues: Whether the appellant, engaged in building bodies on duty-paid chassis, was entitled to concessional duty under Notification No. 462/1986-CE on the strength of a fuel-efficiency certificate held by the chassis supplier.

Analysis: The relevant notification granted concession only to fuel-efficient light commercial motor vehicles satisfying the prescribed fuel-efficiency test and certification requirements issued by the competent authority and the designated Government officer. Though body building on a chassis amounts to manufacture under Note 5 of Chapter 87 and the appellant is therefore treated as a manufacturer of motor vehicles, that by itself does not satisfy the specific conditions of the exemption. The appellant did not possess the requisite certificate, and the certificate, if any, held by the supplier of the chassis could not be treated as sufficient compliance with the notification.

Conclusion: The appellant was not eligible for the concessional rate of duty under Notification No. 462/1986-CE.

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