Entry tax cannot be expanded by implication: tractor parts and accessories are outside the taxable schedule under the statutory scheme.

Parts and accessories of tractors were held not exigible to entry tax under the Karnataka Entry Tax Act, 1979 because tax liability arises only for goods expressly included in the First Schedule. The entry for machinery and its parts and accessories could not be stretched to tractors, as tractors are agricultural machinery and fall outside that entry; the Second Schedule exemption for agricultural machinery confirmed that position. The court also rejected the revenue's attempt to levy tax merely because tractor parts were not separately named, and held the commissioner's circular inconsistent with the statutory scheme.

---

---

Issues: Whether parts and accessories of tractors are exigible to entry tax under the Karnataka Entry Tax Act, 1979.

Analysis: Liability to entry tax under the Act arises only in respect of goods expressly included in the First Schedule. The relevant entry covering machinery and its parts and accessories could not be extended to tractors, since tractors are agricultural machinery and are outside the scope of that entry. The exemption for agricultural machinery in the Second Schedule reinforced that position. The court rejected the revenue's attempt to sustain the levy by treating parts and accessories of tractors as taxable merely because they were not separately named. The commissioner's circular, which proceeded on that basis, was inconsistent with the statutory scheme.

Conclusion: Parts and accessories of tractors are not exigible to entry tax under the Act, and the circular supporting the levy is unsustainable.

Ratio Decidendi: A taxing entry cannot be enlarged by implication to cover goods not plainly included, especially where the statutory scheme shows that the underlying machinery is exempt as agricultural machinery.

---