Nope, those are Russian GAZ-AA headlights. That is a photo of a 1937 custom made Ukrainian ambulance on a Russian GAZ-AA chassis and cab. The license plate is from Kiev and the horn looks to be a GAZ-AA horn, and the headlights are standard GAZ-AA headlights painted body color, etc. Note also the trafficators on either side of the vertical part of the windshield frame.