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14. In our considered view, there is no substance in the contentions raised by the appellants The State is not bound to tax everything. It is at liberty to tax the end-product or the product at stages. A bare reading of the entries leads to an inference that the bodies built for the motor vehicle are squarely covered by Heading No. 87.07 Nothing has been specified that bodies built in a particular way only are to be treated the bodies as envisaged by Heading No. 87.07. The process of manufacturing bodies is not an essential ingredient for the payment of the excise duty, nor the end-product produced by the body building is one of the components of a motor vehicle which end-product can be termed as motor vehicle. Various types of motor vehicles are taken in the trade and recoganised by, the consumer which have been charged with the excise duty specifically, as would be obvious from the Entries in the Schedule, as mentioned above. There is no gainsaying that while exempting the excisable goods which is in the negative form, i.e. except goods specified in the Notification, dated March 1, 1986, all other goods have been accepted. It has been specifically provided that the goods referred to under Heading No. 87 07 are not excisable Reading the entries as put forth by the counsel for the appellants would result in dreconian rule of law and would produce an unjust result inasmuch as the vehicle shall become liable for tax twice over as chassis alone has been made liable for excise as a separate item under Heading No. 87.06 at a particular rate, while the motor vehicle have been excised separately under Heading Nos. 87.02 to 87 04. The basic terrafirma of the Notification meaning that bodies have been independently excised. The reason deployed by the appellant to the effect that building of a body on the chassis itself amounts to manufacture of a motor vehicle is bereft of any substance. Any single act in the process of manufacturing an end-product cannot possess the attributes of production of the end-product. The only conclusion that can be drawn is that the body building is not the same as the manufacture of complete motor vehicle. It may be a link in the whole process and the Legislature has taxed it as an independent item. It is not unkown that in order to encourage subsidiary industries and the small scale units, the Legislature thinks it proper to exempt . such industries or units from the excise duty. However, they still kept the impost if the body is built as part of the integral process of manufacturing the vehicle. It is not disputed that in the trade body building is taken as an independent item and building of it is not understood as manufacturing of a motor vehicle. No body builder has has been described to be a manufacturer of motor vehicle. It does not appeal to the reason that merely body being built on the chassis will deprive it of its character as a body of the motor vehicle. It would still continue to partake the colour and name of the article known in the trade, i.e. body building. It is in the eyes of those who are dealing with the commodity and in commercial parlance that the body is treated as distinctive character and identity from the end-product. The interpretation put forward by the appellants would lead to an illogical result. There is no reasonable basis for the appellants to treat differently the bodies built on the chassis itself, and those built away from the chassis and then mounted on the chassis. The only intelligent deduction from the basic design appears to be, from reading of the entries as well as charging Section 3 and Notification No. 175/86-C.E., dated March 1, 1986, as well as the Schedule and subsequent Notification No. 162/86-Central Excise, dated March 1, 1986, that building or process of manufacturing or fabrication of bodies would not partake the character of manufacture of motor vehicle which may be used for the purpose of carriage of goods or passengers. Since the respondents are not manufacturing any motor vehicle, they are not liable to take any licence Otherwise also, as observed in Porritts and Spancer (Asia) Ltd. v. State of Haryana, (1978) 42 S. T. C. 433 it is the functional character that a product is so identified which is identified in the mind of the consumer.