Post-sale transport charges excluded from taxable turnover where supply and transportation were separate contractual arrangements.

Transport charges separately shown in the purchase order and contract were treated as part of a distinct transportation arrangement, not the sale price. On that construction, the charges were incurred after the sale, the commodity was sold ex-godown, and they were deductible from taxable turnover. The court also held that the final fact-finding authority's interpretation was neither perverse nor wholly unreasonable, and where two views were possible, the view favourable to the assessee had to be adopted. The revision therefore failed.

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Issues: Whether transport charges separately shown in the purchase order and contract formed part of the sale price and taxable turnover, or were deductible as post-sale charges.

Analysis: The contract and purchase order were construed as disclosing two distinct arrangements, one for supply of material and another for transportation, with the respective charges shown separately. On that construction, the transport charges were incurred after the sale and the commodity was sold ex-godown. The interpretation adopted by the final fact-finding authority was neither perverse nor wholly unreasonable, and where two views were possible, the view favouring the assessee was to be preferred.

Conclusion: The transport charges did not form part of the sale price or taxable turnover and were deductible; the revision failed.

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