Entry tax valuation excludes post-entry freight and insurance, while liability on imported goods was upheld.

Entry tax liability on imported machinery and crude oil was upheld against the assessee, with the Tribunal's treatment of the cited authorities left undisturbed on those questions. On valuation, only expenses incurred up to the point the goods are brought into the local area form part of the taxable value; customs duty, port charges, freight and insurance incurred after entry are excluded. Charges attributable to internal movement or use after entry could not be added, while pre-entry expenses remained includible. The revision therefore succeeded only in part, and the Tribunal's order was modified to that extent.

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Issues: (i) Whether entry tax was payable on the imported machinery and crude oil and whether the Tribunal was right in distinguishing the cited decisions on the scope of entry tax liability. (ii) Whether customs duty, port charges, freight and insurance incurred after the goods entered the local area could be included in the value of goods for entry tax purposes.

Issue (i): Whether entry tax was payable on the imported machinery and crude oil and whether the Tribunal was right in distinguishing the cited decisions on the scope of entry tax liability.

Analysis: Questions relating to liability of entry tax on the imported machinery and crude oil were treated as covered by the statutory scheme governing entry of goods into local areas. The relevant provisions were applied to hold that the assessee's challenge on these issues could not succeed. The Tribunal's view on the cited authorities was not found to warrant interference on these questions.

Conclusion: The questions were answered against the assessee.

Issue (ii): Whether customs duty, port charges, freight and insurance incurred after the goods entered the local area could be included in the value of goods for entry tax purposes.

Analysis: The governing principle applied was that expenses incurred by the importer only up to the stage of bringing the goods into the local area form part of the value of goods, whereas expenses incurred after the goods are inside the local area do not. On that basis, charges attributable merely to internal movement, use or accounting after entry into the local area could not be loaded into the taxable value, though charges incurred before the goods crossed into the local area would remain includible.

Conclusion: The questions were answered partly in favour of the assessee and the Tribunal's order was modified to that extent.

Final Conclusion: The revision succeeded only in part: the entry tax liability issues were decided against the assessee, while the valuation issue was accepted to the extent that post-entry expenses could not be included in the value of goods, with consequential reconsideration by the Tribunal.

Ratio Decidendi: For entry tax, only those expenses incurred by the importer up to the point when goods are brought into the local area are includible in the value of goods; expenses incurred after entry into the local area are excluded.

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