Entry tax on mining inputs sustained where iron and steel were found to be used in business operations, not staff quarters.

Iron and steel purchased and used as equipment in the course of mining business were held exigible to entry tax, because the supplementary statement of the case showed business use rather than use for construction of staff quarters. The Court accepted the Board of Revenue's factual conclusion and held that the assessee's contrary assertion did not change the taxable character of the purchases. On that basis, the issue was resolved against the assessee and in favour of the Revenue.

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Issues: Whether the purchase of iron and steel used by the assessee in the construction of staff quarters in the remote areas of the mines was in the course of business of mining so as to attract entry tax.

Analysis: The supplementary statement of the case clarified that the iron and steel purchased by the assessee was used in the mining business and not for construction of staff quarters. On that factual basis, the goods were treated as equipment used in the business, making them liable to entry tax. The Court accepted the Board of Revenue's conclusion that the assessee's claim did not alter the taxable character of the purchases.

Conclusion: The issue was answered against the assessee and in favour of the Revenue.

Ratio Decidendi: Goods purchased and used as equipment in the course of the mining business are exigible to entry tax, and a contrary assertion of use for staff quarters cannot prevail where the record shows business use.

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