Entry tax exemption operates prospectively when inserted mid-year, and the levy is tied to entry of goods, not annual taxation.

Entry tax under the Karnataka Act is triggered by the entry of scheduled goods into a local area; the monthly advance payment and annual assessment machinery affect only computation and collection, not the character of the levy. The tax is therefore not an annual tax. A corrigendum inserted mid-year that creates a new entry-tax exemption, without an express retrospective date, operates prospectively from its publication date and does not extend to the earlier part of the financial year. The stated result is that the exemption could not be applied for the full assessment year.

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Issues: (i) whether the levy of entry tax under the Karnataka Tax on Entry of Goods Into Local Areas for Consumption, Use or Sale Therein Act, 1979 is an annual tax; and (ii) whether an exemption inserted by a corrigendum issued in the middle of the year, without an express effective date, applies for the entire financial year.

Issue (i): Whether the levy of entry tax under the Karnataka Tax on Entry of Goods Into Local Areas for Consumption, Use Or Sale Therein Act, 1979 is an annual tax.

Analysis: The charging event under the Act is the entry of scheduled goods into a local area for consumption, use or sale therein. The scheme of the Act shows monthly advance payment, yearly returns and yearly assessment machinery, but the mode of quantification does not determine the character of the levy. The taxable event is the entry of goods, and the levy attaches on that event; only computation and collection are postponed. The Act therefore does not create a yearly or annual tax in the sense contended.

Conclusion: The levy is not an annual tax; it is a tax arising on the taxable event of entry of goods, with monthly and annual assessment machinery.

Issue (ii): Whether an exemption inserted by a corrigendum issued in the middle of the year, without an express effective date, applies for the entire financial year.

Analysis: The corrigendum did not merely clarify an existing entry-tax exemption; it inserted a new exemption for entry tax. In the absence of any express date giving retrospective operation, the exemption notification takes effect prospectively from the date of issuance/publication. The principle applicable to yearly sales-tax schemes does not govern a levy of this nature, and a corrigendum cannot be treated as relating back so as to cover the earlier part of the financial year.

Conclusion: The exemption operates only prospectively from 27 July 2000 and does not apply to the period from 1 April 2000 to 26 July 2000.

Final Conclusion: The revision petition fails because the assessee was not entitled to treat the entry tax exemption as operative for the entire assessment year, and the Tribunal's order was sustained.

Ratio Decidendi: For entry tax, the taxable event is the entry of goods into the local area, and an exemption introduced without an express retrospective date operates only prospectively from the date it is brought into force.

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