Municipal import rules governed terminal tax on goods brought into limits, even when later taken outside those limits.

Goods brought by a consignee into municipal limits from a railway station were treated as "imported" under the municipal tax scheme, even though they were later carried onward to a destination outside those limits. The governing statute and terminal tax rules defined import by reference to bringing goods into the tax limits from outside them and treated the consignee or person in possession as the importer. On that plain reading, terminal tax was held to be leviable, and reliance on octroi provisions and authorities under different statutory settings was rejected as inapposite.

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Issues: Whether goods received at the railway station and carried into the municipal limits on their way to a place outside those limits are "imported" within the meaning of the municipal tax provisions so as to attract terminal tax.

Analysis: The power to levy a tax on goods imported into the municipality was traced to the municipal statute and the terminal tax rules framed under it. The rules defined "import" as the bringing of goods into the terminal tax limits from outside those limits, and also treated the consignee or person in possession as the importer. On the plain meaning of the word and the governing rules, goods brought by the consignee into the municipal limits were held to be imported within the statutory scheme, even if they were later taken onward to another destination outside the municipality. Reliance on octroi provisions and on cited authorities dealing with different statutory settings was rejected as inapposite.

Conclusion: The goods were held to be imported within the municipal limits and terminal tax was lawfully leviable. The plaintiff's claim for declaration and refund failed.

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