Individual-value test for entry tax applies to machinery and spare parts, not the composite value of multiple items.

Under the U.P. entry tax schedule, taxability turned on the value of each identifiable machine or spare part, not on the aggregated value of multiple distinct items imported together. The High Court applied strict construction of the taxing entry and held that only a single machinery or an individual spare part valued at Rs. 10,00,000 or more attracted entry tax. Multiple machines or parts below that threshold did not become taxable merely because their composite value exceeded the limit. The Commissioner's circular was consistent with this individual-value test, and the earlier view adopting that approach was followed.

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Issues: Whether entry tax under Schedule Entry 2 of the U.P. Tax on Entry of Goods into Local Areas Act, 2007 could be levied on the composite value of different machinery and spare parts imported through a single declaration form, or only on a single machinery or individual spare part whose value exceeded Rs. 10,00,000/-.

Analysis: The taxing entry applies to machinery and spare parts of machinery valuing Rupees ten lakhs or more. The valuation test is therefore attached to the individual machinery or the individual spare part, not to the aggregated value of several distinct items imported together. A circular issued by the Commissioner also clarified that a single machine above the threshold remains taxable even if broken into parts before import, but multiple distinct machines or parts below the threshold do not become taxable merely because their composite value exceeds the limit. The revenue's approach would permit artificial bifurcation or aggregation to create taxability, which is inconsistent with strict construction of a taxing entry. The earlier view accepting the individual-value test was followed.

Conclusion: Entry tax could be levied only on a single machinery whose value exceeded Rs. 10,00,000/- or on an individual spare part whose value exceeded Rs. 10,00,000/-. The composite value of different machinery or spare parts imported together was not relevant.

Ratio Decidendi: Under a taxing entry framed by reference to value, taxability depends on the value of each identifiable taxable item and not on the aggregated value of separate items imported together.

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