Post-sale loading and transport charges are excluded from purchase turnover once delivery is complete at the site.

Amounts incurred by the purchaser after delivery of fly ash at the thermal power station site, including drying, loading, transport and unloading charges, were held to be post-sale expenses and not part of the consideration paid or payable for the purchase. As the sale was complete on acceptance of delivery ex-site and the buyer bore removal at its own risk and expense, those charges could not be included in purchase turnover for levy under section 7A of the Tamil Nadu General Sales Tax Act, 1959. The revenue's contention to include such expenditure in taxable turnover therefore failed, and the question of law was answered in favour of the assessee.

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Issues: Whether loading charges, transport charges and unloading charges incurred by the purchaser after delivery of fly ash at the thermal power station site formed part of the purchase turnover for levy of tax under section 7A of the Tamil Nadu General Sales Tax Act, 1959.

Analysis: The delivery of fly ash was found to have taken place at the site of the thermal power station itself, and the contract required the dealer to remove the material at its own risk and expense. On those findings, the sale was complete when delivery was accepted ex-site, and the expenses incurred thereafter for drying, loading, transporting and unloading were only post-purchase expenses. Such expenditure was not part of the consideration paid or payable for the purchase and could not be included in the purchase turnover. The reasoning was consistent with the earlier decisions relied on, which held that expenses incurred by the purchaser after the sale was complete do not form part of taxable turnover.

Conclusion: The charges incurred after delivery were not includible in the purchase turnover under section 7A, and the question of law was answered in favour of the assessee.

Final Conclusion: The revision was not maintainable on the revenue's contention, as the disputed expenditure was held to be outside the taxable purchase turnover.

Ratio Decidendi: Amounts incurred by the purchaser after delivery and completion of the sale are post-sale expenses and do not form part of the purchase price or purchase turnover for levy of tax.

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