Entry tax is payable on the declared entry value, not an internal Equalized List Price under the taxing statute.

Entry tax on goods brought into a local area was held payable on the stock transfer price declared at entry, because the statutory scheme fixed the taxable base by reference to the value of goods on entry and did not recognise the dealer's Equalized List Price. The court held that an internal pricing mechanism could not override the plain language of the Entry Tax Act, and that nothing can be added by implication to a taxing statute. The assessee's challenge failed, with no substantial question of law arising.

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Issues: Whether entry tax on goods brought into the local area was to be levied on the stock transfer price declared in Form F or on the Equalized List Price adopted by the dealer.

Analysis: The Entry Tax Act levies tax on the entry of goods into a local area and defines the taxable base by reference to the value of goods at the time of entry. The statutory scheme in Sections 2(aa), 2(b), 2(l), 3(a) and 4 of the Entry Tax Act does not recognise Equalized List Price as a basis for levy. Equalized List Price was only an internal pricing mechanism devised by the dealer for sale of goods and could not override the value declared at entry. In a taxing statute, nothing can be added by implication, and equitable considerations cannot control the plain language of the enactment.

Conclusion: The entry tax was correctly levied on the stock transfer price declared at the time of entry, not on the Equalized List Price, and the contention of the assessee was rejected.

Final Conclusion: No substantial question of law arose, and the challenge to the levy failed.

Ratio Decidendi: In the absence of any statutory provision recognising a dealer's internal equalized sale price, entry tax is payable on the value of goods as declared on entry into the local area, and a taxing statute must be applied strictly without importing extraneous considerations.

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