Freight and transport subsidy on imported coal are part of assessable turnover for entry tax purposes.

Freight charges and transport subsidy paid in connection with the import and delivery of coal formed part of the purchase price and assessable import value for entry tax purposes. Applying settled principles on consideration for goods and the statutory definition of import value, the Court held that expenses integrally connected with completing the purchase are includible in turnover and are not post-sale or excludible charges. Freight paid or payable, including transport-related subsidy linked to the supply chain, therefore had to be added to the tax base. The challenge to exclusion of these amounts failed.

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Issues: Whether the freight charge and transport subsidy relating to import of coal were excludible from the import value or turnover for the purpose of levy of entry tax.

Analysis: The assessment proceeded on the footing that the dealer had paid the freight on imported coal and that such expenditure formed part of the total price for computing turnover. The Court applied the settled principle that amounts paid as part of the consideration for the purchase of goods, including expenses necessary for completing the sale, form part of the purchase price. It relied on the Supreme Court authorities holding that transport subsidy or similar freight-related payments, when integrally connected with the purchase and delivery of goods, are includible in the turnover and are not post-sale expenses. The statutory definition of import value under the Entry Tax law also required inclusion of freight charges that are paid or payable.

Conclusion: The freight charge and transport subsidy were not excludible from the assessable turnover or import value for entry tax purposes, and the challenge failed.

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