Entry tax valuation on stock transfers must follow wholesale local market value, not the assessee's book sale value.

For entry tax on goods brought into a local area by stock transfer, valuation must be made under the statutory definition in Section 2(h) by reference to the wholesale value of similar goods sold inside the local area at the relevant time. The assessee's actual sale value recorded in its books is not the correct benchmark for this computation. Because the assessment did not address the wholesale value of similar goods sold locally, the valuation adopted by the revenue was contrary to law and the matter required fresh determination on the proper basis.

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Issues: Whether, for levy of entry tax on goods brought into the local area by stock transfer, the assessing authority was required to compute value on the basis of wholesale value of similar goods sold inside the local area, or could rely on the assessee's actual sale value.

Analysis: The valuation had to conform to the statutory definition of value of goods under Section 2(h) of the Entry Tax Act. Where the goods were admittedly brought into the local area by stock transfer, the relevant benchmark was the wholesale value of similar goods sold inside the local area at the relevant time. The sale value recorded in the assessee's books had no relevance for this computation. As there was no discussion or finding on the wholesale value of similar goods sold within the local area, the assessment could not be sustained.

Conclusion: The valuation adopted by the revenue was held to be contrary to law, and the matter was required to be reconsidered on the correct basis.

Final Conclusion: The revision succeeded and the assessment proceedings were sent back for fresh determination in accordance with law.

Ratio Decidendi: For entry tax on goods brought by stock transfer, the assessable value must be determined with reference to the wholesale value of similar goods sold in the local area, not the assessee's actual sale value.

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