Purchase value under motor vehicle tax law excludes VAT and added tax elements, limiting levy to invoice value.

For levy of tax under the Kerala Motor Vehicles Taxation Act, 1976, "purchase value" is confined to the value shown in the original purchase invoice. The definition in section 2(e) is exhaustive because it uses the word "means", and the proviso confirms that comparable valuation is used only where the invoice is unavailable. VAT and any additional tax element reflected in or added to the invoice value are not part of purchase value. Tax under the Act must therefore be computed only on the invoice value, and a contrary demand is unsustainable.

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Issues: Whether, for levy of tax under the Kerala Motor Vehicles Taxation Act, 1976, the "purchase value" of a motor vehicle includes the VAT component and any additional tax element reflected in or added to the invoice value.

Analysis: The Act levies one-time tax on new motor vehicles with reference to the purchase value. Section 2(e) defines "purchase value" as the value of the vehicle shown in the original purchase invoice, and the use of the word "means" makes the definition exhaustive and restrictive. The proviso to section 2(e), which applies where the invoice is unavailable, also confirms that the purchase value is to be ascertained from comparable vehicle value or customs/excise valuation, and not by adding taxes or other charges on top of the vehicle value. On that construction, VAT is not part of the purchase value for the purpose of tax under the Act.

Conclusion: The VAT component and any additional tax element cannot be included in the purchase value; tax under the Act must be computed only on the value shown in the original purchase invoice, so the demand contrary to that basis is unsustainable and the appellant is entitled to registration on that footing.

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