Purchase invoice value governs motor vehicle tax; manufacturer portal values cannot override the statutory definition.

Motor vehicle tax under the Kerala Motor Vehicle Taxation Act, 1976 must be computed on the purchase value shown in the genuine dealer invoice, because section 2(e) defines purchase value by reference to that invoice and includes applicable taxes and duties. The provisos apply only to dealer discount or rebate, imported vehicles, other non-purchase acquisitions, or cases where no invoice is available. An administrative or software-based manufacturer portal value cannot replace the statutory invoice value, and executive instructions cannot override the Act. On that basis, tax had to be levied on the invoice value and permanent registration granted accordingly.

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Issues: Whether motor vehicle tax under the Kerala Motor Vehicle Taxation Act, 1976 was payable on the purchase value shown in the dealer's invoice or on the higher value uploaded in the manufacturer's web portal.

Analysis: Section 2(e) defines "purchase value" as the value shown in the purchase invoice and includes applicable taxes and duties. The first proviso excludes only dealer discount or rebate, and the second proviso applies only where the vehicle is imported, otherwise acquired than by purchase, or the invoice is unavailable. On the facts, the vehicle was purchased through a regular invoice, the invoice was available, and there was no case of manipulation, discount-based understatement, or exclusion of tax components. The statutory text did not permit substitution of the invoice value by the manufacturer's portal value, and accepting that position would amount to rewriting the Act. The court also held that executive instructions or software settings could not override the clear statutory definition.

Conclusion: The tax had to be computed at 21% of the invoice value shown in the purchase invoice, and the respondents were bound to accept that amount and grant permanent registration.

Ratio Decidendi: Where the statute expressly defines purchase value by reference to the purchase invoice and the invoice is genuine and complete, tax must be levied on that invoice value and cannot be substituted by an administrative or software-based manufacturer value.

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