Apportionment in composite bus sales extends to route permits and route value, not just vehicle price.

In a composite sale of buses with route permits, the consideration was not confined to the vehicles alone and could be apportioned to reflect the separate value of the permits and the earning capacity of the route. The absence of a distinct permit price in the agreement was not a valid basis to reject apportionment, and if the assessee's allocation appeared unreasonable, the assessing authority had to determine a proper division of the consideration. The entire amount could not be treated as the sale price of the buses merely because the permit component was not separately stated.

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Issues: Whether, in a composite sale of buses and route permits, the sale consideration had to be apportioned between the vehicles and the permits, and whether the revenue could treat the entire consideration as the sale price of the buses.

Analysis: The agreement showed that the transfer was not confined to the buses alone but included the route permits as well. A consolidated price may legitimately contain an element attributable to the earning capacity attached to the route, and the absence of a separate figure in the agreement was not a valid reason to deny apportionment. If the allocation made by the assessee was thought to be unreasonable, it was for the assessing authority to determine a proper apportionment; the entire amount could not be treated as vehicle value merely because the agreement did not separately specify the permit component. The earlier decision on transfer of buses with permits supported the view that part of the consideration is attributable to the route value.

Conclusion: The consideration had to be apportioned between the buses and the route permits, and the assessee's allocation could not be rejected on the sole ground that the agreement did not separately specify the permit price. The questions were answered in favour of the assessee.

Ratio Decidendi: Where a transfer of buses is part of a composite sale that includes route permits, the consideration is not confined to the vehicles alone and may be apportioned to reflect the value of the permits and the earning capacity of the route.

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