Entry tax liability depends on who caused goods to enter the local area, not where title passed.

Liability to entry tax under section 3(2) of the Karnataka Tax on Entry of Goods into Local Areas for Consumption, Use or Sale Therein Act, 1979 turns on whether the registered dealer brought or caused the goods to be brought into the local area, or took delivery on entry, rather than on the place of sale or passing of title. On the stated contract terms, the dealer undertook delivery, arranged transport, and secured transit insurance, supporting the conclusion that the dealer caused the entry of the goods. The commentary records that this basis supported restoration of the entry tax levy.

---

---

Issues: Whether liability to entry tax under section 3(2) of the Karnataka Tax on Entry of Goods into Local Areas for Consumption, Use or Sale Therein Act, 1979 depends on where title passed or on who caused the goods to enter the local area.

Analysis: Section 3(2) fastens liability on a registered dealer who brings or causes goods to be brought into a local area, or who takes delivery or is entitled to take delivery on entry into the local area. The material question is thus not the place where the sale was completed or where title passed, but whether the dealer caused the entry of the goods into the local area. On the contract terms, the dealer undertook delivery to the purchasers, arranged transport, and secured transit insurance, which supported the conclusion that the entry was caused by the dealer and not by the purchasers.

Conclusion: The respondent was liable to pay entry tax, and the contrary finding of the Tribunal was set aside.

Final Conclusion: The levy of entry tax as confirmed by the assessing authority and the first appellate authority was restored.

Ratio Decidendi: For entry tax under section 3(2), liability turns on who caused the goods to enter the local area, and not on the place of sale or the passing of title.

---