Entry tax valuation includes freight up to market entry, as the statutory value extends beyond invoice price.

Freight incurred for transporting goods into the Calcutta Metropolitan Area is includible in the value of goods for entry tax purposes under the applicable valuation scheme. Rule 12 was read contextually, so the declared value was not confined to invoice price or to the items expressly listed in the rule; it had to reflect the real saleable value of the goods at the relevant point of entry. On that construction, transportation-related expenditure up to entry into the market area could not be excluded merely because it was not separately specified, and the challenge to its addition failed.

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Issues: Whether freight incurred for transportation of goods into the Calcutta Metropolitan Area is includible in the value of goods for levy of entry tax under the applicable Act and Rules, and whether the actual transportation cost up to the check-post alone or equalised freight could be excluded.

Analysis: The valuation scheme under rule 12 of the Rules required declaration of the value of goods for assessment and the statutory components mentioned therein were not exhaustive in the setting of the provision. The phrase used in the rule had to be read in context, and the prescribed value was not confined to the invoice price alone. The earlier binding construction accepted that the value for entry tax purposes in the Calcutta Metropolitan Area must reflect the real saleable value and include transportation-related expenditure up to the relevant point of entry. The Supreme Court authority relied upon was treated as directly governing the field, and the Tribunal held that freight could not be excluded merely because it was not separately listed among the declared items.

Conclusion: Freight was includible in the valuation for entry tax purposes, and the challenge to its addition failed.

Ratio Decidendi: For entry tax valuation under the relevant scheme, the statutory term denoting value must be construed in context to include all components necessary to reach the saleable value of the goods, including freight incurred up to entry into the market area.

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