Dharmada collections are not part of sale price; addition in Goshala and Dharmada accounts was rightly deleted.

Dharmada collections are not part of the sale price or a surcharge on it, because they are paid by customers in addition to the price and the purchase is only the occasion for payment. On that settled characterisation, the Tribunal was justified in deleting the addition in the Goshala and Dharmada accounts, and the deletion was upheld in favour of the assessee.

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Issues: Whether the Tribunal was justified in deleting the addition standing in the Goshala and Dharmada accounts for the relevant assessment year.

Analysis: The answer turned on the settled legal character of Dharmada collections. Such amounts are not part of the price of goods sold, nor a surcharge on that price, because they are paid by the customer in addition to the sale price. The purchase of goods is only the occasion for the payment and not the consideration for the Dharmada amount.

Conclusion: The question was answered against the Revenue and in favour of the assessee, and the deletion of the addition was upheld.

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