Concessional purchase tax and entry tax denied where job-work goods were not manufactured for sale by the registered dealer.

Concessional purchase tax and entry tax were available only where raw material was used to manufacture goods for sale and the conditions in rule 20-B(iii) were fully met. The phrase "for sale" and the requirement that the manufactured goods "shall be sold by the registered dealer" were treated as clear limits on the concession, so mere job-work manufacture followed by return of the goods to the customer was insufficient. As the assessee did not sell the goods as a registered dealer and did not satisfy the attached conditions, the concession was denied. The Supreme Court authority cited by the assessee was distinguished because it construed different statutory language.

---

---

Issues: Whether the assessee was entitled to concessional purchase tax and entry tax on raw material used in galvanising goods as job-work when the manufactured goods were not sold by the registered dealer.

Analysis: The concessional rate under section 7(2) was held to apply only when the goods are manufactured for sale and the conditions in rule 20-B(iii) are satisfied. The expression "for sale" in the provision and the requirement that the manufactured goods "shall be sold by the registered dealer" in the rule showed a clear legislative intent that mere manufacture in the course of job-work, followed by return of the goods to the customer, is insufficient. The Court held that the assessee neither sold the goods as a registered dealer nor satisfied each condition attached to the concession. The Supreme Court decision relied on by the assessee was distinguished because it turned on different statutory language.

Conclusion: The assessee was not entitled to the concessional rate of purchase tax or entry tax.

---