The judgment of the Court was delivered by

PATHAK, J.- The respondent manufactures the bodies of motor vehicles employed as trucks and sells them. In assessment proceedings for the assessment year 1956-57 the Sales Tax Officer determined the turnover of such bodies at Rs. 16,000 and, treating them as component parts of motor vehicles within the meaning of item No. 24 of Notification No. S.T.-905/X dated 31st March, 1956, issued by the State Government under section 3-A of the U.P. Sales Tax Act, computed the tax liability by applying the rate of one anna per rupee. The respondent preferred an appeal contending that a body mounted on the chassis of a motor vehicle was not a component part of the motor vehicle and, therefore, was not an item classified in the aforesaid notification. It should be considered, he urged, as an unclassified item liable to tax at the lower rate mentioned in section 3 of the U.P. Sales Tax Act. The contention found favour with the Judge (Appeals) Sales Tax and he allowed the appeal. The Commissioner of Sales Tax applied in revision and the Judge (Revisions) Sales Tax has dismissed the revision application. At the instance of the Commissioner, the Judge (Revisions) has made the instant reference to this Court for its opinion on the following question :

"Whether under these circumstances the sale of prepared truck bodies would be treated to be that of manufactured component part covered by the relevant notification under section 3-A so as to be charged under section 3-A or not ?"

The Notification No. S.T.-905/X dated 31st March, 1956, declares that the turnover in respect of the goods specified in the list appended is liable to tax with effect from 1st April, 1956, in the case of (a) goods imported from outside Uttar Pradesh, only at the point of sale by the importer and (b) in the case of goods manufactured in Uttar Pradesh, only at the point of sale by the manufacturer, and that such turnover is liable to tax at the rate of one anna per rupee. The list sets out a large number of commodities, and item No. 24 reads :

"Motor vehicles, including motor cars, motor taxicabs, motor cycles and motor cycle combinations, motor scooters, motorettes, motor omnibuses, motor vans and motor lorries.

Chassis of motor vehicles.

Component parts of motor vehicles. Articles (including batteries) adapted for use as parts and accessories of motor vehicles, not being such articles as are ordinarily also used for other purposes than as parts or accessories of motor vehicles."

The question before us is whether the body of the motor vehicle is a component part of it. To decide that question it is necessary to determine first what is a motor vehicle. A motor vehicle is a carriage propelled by a motor. It is a vehicle intended ordinarily for conveying passengers or goods. Now, a component part of an article is one of the parts constituting it. It is an integral part necessary to the constitution of the whole article. Without it, it would not be possible to conceive of the entire article as a whole. Can it be said that the body of a motor vehicle is a necessary part of the motor vehicle ? Learned counsel for the respondent seeks to persuade us that the motor vehicle is a complete unit when it consists of a motor and chassis on wheels and that the body mounted on the chassis is not a necessary part of the motor vehicle. We are unable to accept the contention. To function as a conveyance, the motor vehicle must be capable of accommodating the passengers or carrying the goods intended to be conveyed. If it functions as a stage carriage, it must have a body designed to accommodate passengers. If it is intended to function as a carrier of goods, it must be designed to carry goods. Unless it is so designed, it is incapable of ordinarily discharging the purpose for which it is intended. There can be no dispute that in order to serve that purpose effectively it is necessary for a motor vehicle to have a body mounted on it. The de