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Issues: Whether, for levy of entry tax under the U.P. Tax on Entry of Goods into Local Areas Act, 2007, the expression "value of goods" is to be determined by reference to the purchase price incurred by the importer at the stage of entry into the local area, or by reference to the subsequent sale price realised within the local area.
Analysis: The statutory scheme treats the entry of goods into the local area as the taxing event and defines "value of goods" by reference to the original purchase invoice or bill, together with specified incidental charges connected with purchase and transport up to the point of entry. Charges incurred after the goods enter the local area, including the dealer's internal expenses and profit margin on local sale, do not form part of the taxable value. The computation of entry tax is therefore confined to the stage at which the goods are brought into the local area, and the subsequent sale price cannot be substituted for that value. Support was drawn from the pari materia entry-tax principle that the price prevailing at the time of entry is the relevant base for ad valorem levy.
Conclusion: The taxable value is the purchase price and connected pre-entry charges, not the sale price realised inside the local area. The Tribunal's view treating sale price as the value of goods was unsustainable.