Entry tax on fully built vehicles turns on purchase value including fitted accessories and mounted bodies.

Under the Tamil Nadu Tax on Entry of Goods into Local Areas Act, 1990, entry of a motor vehicle into a local area for use or sale is the charging event, and "motor vehicle" is read with the Motor Vehicles Act. The analysis treats "purchase value" as including accessories fitted to the vehicle, so a chassis sent for body building and returned with the body mounted is assessed on the value of the fully built vehicle, not on the chassis alone. The mounted tanker or body is treated as an accessory for this purpose, and the reduction provision does not displace that basis. Decisions under different statutory schemes are distinguished.

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Issues: Whether a chassis purchased within the State, taken outside for body building and brought back with the body mounted on it, is liable to entry tax on the full vehicle including the mounted body under the Tamil Nadu Tax on Entry of Goods into Local Areas Act, 1990.

Analysis: The relevant definitions under the Act treat entry of a motor vehicle into a local area for use or sale as the charging event, and define "motor vehicle" by reference to the Motor Vehicles Act. The Act further defines "purchase value" to include accessories fitted to the vehicle. Reading these provisions together, the mounted tanker/body was treated as an accessory and the value of the fully built vehicle, not merely the chassis alone, formed the basis for assessment. The assessee was an importer under the Act and the tax liability under Section 3(2) followed accordingly. The reduction provision under Section 4(2) did not displace the assessment on the full vehicle in the facts of the case. The cited decisions from other High Courts were distinguished because they arose under different statutory definitions and schedules.

Conclusion: The full vehicle, including the chassis and the mounted body, was rightly subjected to entry tax, and the assessment was upheld in favour of the Revenue.

Final Conclusion: The writ appeal did not succeed on the merits of the levy; the assessment treating the entire vehicle as liable to entry tax was sustained, while the challenge to the rate of tax was left to be worked out in the statutory appellate forum.

Ratio Decidendi: Where the charging statute defines purchase value to include accessories fitted to the vehicle and the imported vehicle returns in a fully built form, tax is leviable on the value of the complete vehicle rather than on the chassis alone.

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