Tractor tyres and tubes excluded from concessional "tractors and their parts" entry, attracting the general sales tax rate.

The sales tax notification granting a concessional rate for "tractors and their parts" was read narrowly, and tractor tyres and tubes were treated as outside that entry because the schedule did not specifically include them. The interpretive contrast with other entries, where tyres and tubes were expressly named alongside the principal vehicle or machine, supported the view that their omission was deliberate. On that basis, tractor tyres and tubes remained liable at the general sales tax rate rather than the concessional 5% rate.

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Issues: Whether tractor tyres and tubes were covered by the entry for "tractors and their parts" under the relevant sales tax notification, so as to attract the concessional rate of tax.

Analysis: The notification granted 5% sales tax on "tractors and their parts". The entry did not specifically mention tyres and tubes, unlike other entries in the schedule where tyres and tubes were expressly included along with the principal vehicle or machine. On that basis, tractor tyres and tubes were treated as not falling within the concessional entry. The surrounding materials also indicated that such goods had been charged at the general rate.

Conclusion: Tractor tyres and tubes were held not to be covered by the concessional entry and were taxable at the general rate of 7%.

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