Purchase turnover and transport charges: delivery-at-mill contracts keep recovered carriage costs within the assessable purchase price.

Where a sugar mill's contracts required sugarcane to be delivered at the mill premises, transport arranged by the mill was treated as a facilitative expense and not as a shift in the contractual place of delivery. The statutory purchase price remained the assessable purchase price, and transport charges advanced by the mill but recovered from growers were part of the purchase transaction rather than a separate post-purchase expense. On that basis, exclusion of the transport charges from purchase turnover was not permitted, and the full purchase price was upheld for assessment.

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Issues: Whether transport charges initially paid by the sugar mills for arranging carriage of sugarcane from the growers could be excluded from the purchase turnover as post-purchase expenses.

Analysis: The agreements and registration forms showed that the sugarcane growers remained bound to deliver cane at the mill premises. The arrangement of lorries by the mills was only a to enable timely transport and did not alter the contractual situs of delivery or convert the transaction into a purchase at the fields. The billing practice also treated the statutory price as the purchase price and the transport charges as amounts payable by the growers but advanced and later recovered by the mills. On these facts, the transport charges were not a separate element deducted from the purchase price but formed part of the amount recoverable in the course of the purchase transaction.

Conclusion: The transport charges could not be deducted from the assessable purchase turnover, and the claim for exclusion failed.

Final Conclusion: The revision cases were dismissed, with the assessment of the full statutory purchase price, without reduction of the transport charges, being upheld.

Ratio Decidendi: Where the contract requires delivery at the buyer's premises and the buyer merely advances transport expenses later recovered from the seller, such charges are not post-purchase expenses deductible from the purchase turnover.

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