Light commercial vehicle classification for exemption requires trade understanding and relevant technical factors, not dictionary meaning alone.

Ambulances and cash vans claimed exemption as light commercial vehicles under Notification No. 463/86, but the classification could not rest on dictionary meaning alone because the expression was undefined and the lower authority had not examined trade understanding, payload capacity, engine type, or the relevant Board instructions. The finding on eligibility for exemption was therefore unsustainable. The order was set aside and the matter was remanded for de novo adjudication after hearing the appellants.

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Issues: Whether ambulances and cash vans were entitled to the benefit of Notification No. 463/86 as light commercial vehicles, and whether the matter required fresh adjudication.

Analysis: The expression "light commercial vehicles" was not defined in the notification. The lower authority had relied mainly on dictionary meaning without properly examining trade understanding, payload capacity, the type of engine fitted, or the Board's instructions said to have bearing on the classification. In the absence of such enquiry and proper consideration of the relevant material, the finding on eligibility for exemption could not be sustained.

Conclusion: The order was set aside and the matter was remanded for de novo adjudication after hearing the appellants.

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