Bus and truck bodies on customers' chassis fall outside the higher motor vehicle tax entry and attract the lower rate.

Bus and truck bodies built on customers' chassis were treated as component parts, not as spare parts of motor vehicles, so they did not fall within the higher schedule entry taxing motor vehicles, chassis, tyres, tubes and spare parts at 12%. The schedule was read strictly: where the legislature intended to cover both components and spare parts, it said so expressly in other entries. Because the motor-vehicle entry did not include such components, these bodies were taxable only under the residual lower rate applicable to goods not specifically covered, and were correctly taxed at 5%.

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Issues: Whether bus and truck bodies built on customers' chassis are taxable at the higher rate applicable to motor vehicles and spare parts, or at the lower rate applicable to goods not specifically covered by the higher entry.

Analysis: The relevant schedule entry taxed motor vehicles, chassis, tyres, tubes and spare parts at 12%. Bus and truck bodies were held not to be spare parts of motor vehicles. The schedule itself showed that where the legislature intended to include components as well as spare parts, it did so expressly in other entries. Since components were not included in the motor-vehicle entry, and bus and truck bodies were only component parts, they could not be brought within the higher taxing entry.

Conclusion: Bus and truck bodies were not taxable at 12% under the motor-vehicle entry and were correctly taxed at 5%.

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