Statutory definition of purchase price governs drawback calculation under sales tax rules, rejecting a reduced real-price reading.

For the second proviso to rule 41A of the Bombay Sales Tax Rules, 1959, the term "purchase price" was held to take its statutory meaning under section 2(22) of the Bombay Sales Tax Act, 1959. The context of rule 41A did not justify a departure from that defined meaning, and the rule's own formula showed that any intended reduction was expressly provided for. Sales tax was also recognised as forming part of the purchase price under settled law, whether separately recovered or included in the price. The interpretation favoured the Revenue and rejected a narrower "real purchase price" construction.

---

---

Issues: Whether, for the purpose of the second proviso to rule 41A of the Bombay Sales Tax Rules, 1959, the expression "purchase price" means the price as defined in section 2(22) of the Bombay Sales Tax Act, 1959, or the "real purchase price" after deducting profit and sales tax.

Analysis: Rule 41A grants drawback, set-off or refund to a manufacturing dealer and the second proviso requires deduction of 3 per cent of the purchase price from the aggregate of the eligible amounts. The expression "purchase price" occurs both in the rule and in the statutory definition in section 2(22). Where the statute defines a term, that definition applies to the Act and the Rules unless the context requires a different meaning. The context of rule 41A did not justify departure from the statutory definition. The formula in clause (c) of rule 41A itself shows that where reduction is intended, the rule specifically provides for it. The Court also noted that sales tax forms part of the purchase price under settled law, whether separately recovered or included in the price.

Conclusion: "Purchase price" in the second proviso to rule 41A means the purchase price as defined in section 2(22) of the Bombay Sales Tax Act, 1959, and not the amount reduced by profit or sales tax. The question was answered in the negative, in favour of the Revenue.

Ratio Decidendi: A statutory term defined in the parent Act must be given that defined meaning in the Rules unless the context clearly requires otherwise, and a rule cannot be interpreted to create a narrower artificial meaning where the legislature has not done so.

---