Motor vehicle body conversion treated as body-building, with FRP-bodied jeeps classifiable under sub-heading 8707.00.

Conversion of duty-paid jeeps fitted with canvas hoods into jeeps with FRP bodies was treated as body-building work on an existing motor vehicle, not as manufacture of a new product. On the facts, replacing the body did not bring into existence a goods item with a different name, character or use, so classification under sub-heading 8707.00 applied. The entry under sub-heading 8703.00 was therefore rejected, and the comparison with bodies built on non-duty-paid chassis received under Rule 56-B was held inapposite.

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Issues: Whether duty-paid jeeps with canvas hoods, when converted into jeeps fitted with FRP bodies, were classifiable under sub-heading 8703.00 or under sub-heading 8707.00, and whether the process resulted in emergence of a new product.

Analysis: The relevant distinction was between body-building on chassis and conversion of an already duty-paid motor vehicle. The vehicle received from customers and dealers was a jeep with a canvas hood, and the work done consisted of replacing that body with an FRP body. On those facts, no new product having a different name, character or use emerged. The activity was treated as one of building bodies for motor vehicles, for which sub-heading 8707.00 was the appropriate entry. The comparison with bodies built on non-duty-paid chassis received under Rule 56-B was held to be inapposite.

Conclusion: The goods were correctly classifiable under sub-heading 8707.00 and not under sub-heading 8703.00; the assessee's classification was upheld.

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