Tractor cess on separate parts and accessories was not leviable where the levy applied only to tractors as cleared.

Tractor cess was held not to apply to parts, components or accessories cleared separately from tractors, because the levy notification operated on tractors as such and not on component-based clearances. The reasoning distinguished the tractor from its individual parts and rejected any equation between the vehicle and its accessories. Reliance was placed on the circular reasoning for automobile cess, which indicated that cess is not to be levied again on separate body-building or analogous component clearances where the charge is intended only on the vehicle as cleared. The practical effect is that separate clearance of tractor parts does not attract tractor cess under the notification considered.

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Issues: Whether tractor cess was leviable on parts, components and accessories of tractors cleared by the appellant.

Analysis: The levy notification was held to operate on tractors and not on the parts, components or accessories thereof. The parts and accessories of a tractor could not be equated with the tractor itself. Support was taken from the reasoning in the cited circular concerning automobile cess, which indicated that cess is not to be levied again on separate body building or analogous component-based clearances where the levy is intended on the vehicle as cleared.

Conclusion: Tractor cess was not leviable on the parts and components of tractors cleared by the appellant.

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