Indirect Taxes

Sales Tax

Prem T. Chhatpar

Entry tax on imports

Levy of Entry tax on imports from outside the “country” not permissible under the Assam entry Tax Act, 2001. The Act seeks to levy tax on entry of goods into the local area from another local area or from outside the state but does not envisage levy of tax on goods brought into the local area from outside the country. The Legislature had consciously used the words “including a place outside the state” but did not mean to convey “outside the country” since the distinction between the two is quite obvious.

Primus Imaging P. Ltd. vs. State of Assam and Anr. (2007) 9 VST 528 (Gauhati)

Branch Transfer — Form F mandatory for all interstate movement of goods other than by way of sale

The Allahabad HC has held that production of Form F is mandatory to discharge the burden placed by Section 6A of the CST Act since Section 6 is expressly made subject to the other provisions contained in the Act. Form F would be required even if the goods were sent to a Job worker outside the state under a bailment (or received back) and not pursuant to a contract of agency since Form F is required to be produced in all cases where movement of goods other than by way of sale is to be proved. The Court drew support from Ashok Leyland (2004) 3 SCC 1 and the fact that Sec. 2(g)(ii) of the CST Act considers with transfer of property in goods, whether as goods or in some other form, involved in the execution of a inter state works contract as a sale.

Ambica Steels Ltd. vs. State of U.P and Others – Writ Petition No. 302 of 2007 decided on 17-8-2007 by the Allahabad High Court

Omission to deduct/shortfall in deduction of tax at source – Implications

The S.C. has held that in the event of non deduction or short deduction of income tax at source as per the provisions of the Income Tax Act, 1961 the CBDT Circular No. 275 /201/95-IT(B) dated 29.1.1997 would operate and no demand of tax could be enforced against the Tax-Deductor if taxes have been paid by the deductee-assessee. However, the liability to charge interest under Sec. 201(1A) till the date of payment of taxes by the deductee-assessee or the liability to penalty u/s 271C would remain unaltered.

Hindustan Coca Cola Beverage P. Ltd. vs. CIT — 16-8-2007

Form C – Purchase of supporting machinery against Form C valid

Purchase of Lathe Machine for repairs of Moulds used in the manufacture of glass chatons was eligible to be purchased on Form C although the Lathe Machine was not directly used in the manufacture of goods for sale.

Jai Glass – 8 VST 770 (Raj.)

Aggrieved person – Buyer can be an aggrieved person eligible to move an application under the West Bengal Taxation Tribunal Act, 1987 if the seller refuses to challenge the validity of levy of sales tax on the impugned transaction between the buyer and the seller. The WBTT observed that although the seller is the dealer in respect of sales and sales tax, it realizes the tax from the buyer and as such does not ordinarily suffer anything as it is not required to pay from his own fund. In case of any illegal or unjust realization, it is the buyer who suffers and not the seller and as such the buyer could be the “aggrieved person”

BOC India vs. Commissioner, CT (WBTT) 9 VST 573 (WBTT)

Accessories – Meaning

Number plates were “accessories” of vehicles as they add to the convenient use of the motor vehicle – they serve to identify the vehicle. Accessories can be supplementary or subordinate and not necessarily essential for the functioning of the product.

Pragati Silicon P. Ltd. vs. Commissioner of Central Excise 8 VST 705 (S.C.)

Rectification suo motu

Suo motu rectification order is required to be passed within the limitation period - 3 years from the end of the period of assessment and mere initiation of rectification proceedings within the time limit specified above would not be sufficient.

Assam Tea Brokers P. Ltd. 8 VST 621

Interest on delayed refund

Failure by the Department to make refund within 90 days of assessee’s application for refund pursuant to appellate order would entail payment of interest. The Department’s plea to exclude time taken to take approval of the Commissioner in case of high refund amounts and penal proceedings against the assessee was not accepted.

Escotel Mobile Communications Ltd. vs. State of Haryana and Anr. 9 VST 382 (P & H)

Goods in transit through state

Goods in transit from Bihar to Orissa through the state of West Bengal were intercepted for non production of all transport documents and penalty was levied after considering the total value of all goods. The Tribunal held that penalty could not be levied in respect of value of goods that were tax free but was leviable on other taxable goods.

Sri Subir Das Gupta (2007) 9 VST 606 (WBTT)

Deduction for furnace oil used in manufacture of iron and steel

The P & H HC has held that furnace oil was a primary commodity used in the manufacture of iron and steel and without use thereof, production itself was not possible. Thus the furnace oil purchased could be said to have been used or consumed in the manufacture of goods other than tax free goods and the dealer was entitled to deduction of purchase value of furnace oil. If a process or an activity is such an integral part of the ultimate manufacture of goods that in its absence the manufacture may not be commercially expedient, that activity or process must be considered as a manufacturing activity itself and the goods intended for use in that process or activity to be goods required in the manufacture of other goods for sale.

Partap Steel Rolling Mills Ltd. vs. State of Punjab (2007) 9 VST 629 (P & H)