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Issues: Whether tractor cess was leviable on parts, components and accessories of tractors cleared by the appellant.
Analysis: The levy under the notification was held to attach to the tractor itself, and not to its parts or accessories. The Tribunal relied on the text of the cess notification, the statutory scheme under the Industrial (Development and Regulation) Act, 1951 and the applicable Tractor Cess Rules, and held that parts and accessories of a tractor cannot be equated with the tractor. Support was also drawn from the principle reflected in the CBEC circular relating to automobile cess, which recognised that cess is not again attracted on independent body-building or component-based clearance where the levy is intended on the vehicle as cleared from the manufacturer.
Conclusion: Tractor cess was not leviable on the parts, components and accessories cleared by the appellant.