Assessable value and sales tax nexus: prior-period tax liabilities cannot reduce value of later clearances.

Sales tax paid later for disputed liabilities relating to an earlier period could not be deducted from the assessable value of goods cleared in the subsequent years under review. The decisive point was lack of nexus: the additional tax payment was attributable to prior-period clearances, not to the clearances made during 1985-86 and 1986-87. On that basis, the claimed deduction was disallowed and the challenge failed.

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Issues: Whether sales tax paid during the relevant years in respect of clearances made in earlier periods could be deducted while determining the assessable value of goods cleared during 1985-86 and 1986-87.

Analysis: The claim related to additional sales tax paid later on account of disputes for an earlier period. Such payment was not attributable to the clearances made during the succeeding years under appeal. Amounts paid for previous-period sales tax liabilities could not reduce the assessable value of goods cleared during the relevant years, since they had no nexus with those clearances.

Conclusion: The deduction was rightly disallowed and the challenge failed.

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