Entry tax liability turns on proved bringing or causing entry of goods, not mere body-building on customer-supplied chassis.

Entry tax under the Karnataka Tax on Entry of Goods Act, 1979 attaches only when a dealer is proved to have brought, or caused goods to be brought, into the local area, including through the statutory deeming provision. Where the chassis was purchased by the customer and merely supplied to the assessee for fabrication of a bus body in its workshop, the assessee did not itself effect the entry and no factual basis existed to treat it as the person causing that entry. The deeming provision was therefore inapplicable, and the tax demand was unsustainable.

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Issues: Whether the assessee was liable to pay entry tax under the Karnataka Tax on Entry of Goods Act, 1979 on the footing that it had caused entry of chassis into the local area on behalf of its customer.

Analysis: Liability under section 3(2) arises where a registered dealer or dealer liable to register brings or causes goods to be brought into a local area, whether on his own account or on account of his principal, and the Explanation deems the dealer to have brought or caused to be brought the goods where delivery is taken in the specified manner. On the facts found, the chassis had been purchased by the customer and supplied to the assessee for construction of the bus body within its workshop. The assessee did not itself bring the chassis into the local area, nor was there any factual basis to treat it as the person who caused such entry. The deeming provision was therefore inapplicable.

Conclusion: The assessee was not liable to pay entry tax for causing entry of the chassis into the local area, and the demand and concurrent orders were unsustainable.

Ratio Decidendi: Entry tax liability under section 3(2) attaches only when the dealer, on the proved facts, brings or causes the goods to be brought into the local area, and a mere activity of building body on customer-supplied chassis within the dealer's premises does not by itself attract the deeming provision.

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