The petitioner, a company incorporated under the Companies Act, 1956 having its registered office at Madurai, engaged in retail sale of motor vehicles/chassis manufactured by M/s. General Motors India Private Limited and Ashok Leyland Ltd., apart from spares, has its outlet in the State of Karnataka at the address shown in the cause title, is a registered dealer under the Karnataka Value Added Tax Act, 2003 (for short ‘Act’) and Karnataka Value Added Tax Rules, 2005 (for short ‘Rules’).

2. According to the petitioner, during the period April 2006 to January 2008, it effected sales in the following manner:

(A) ASHOK LEYLAND LIMITED:

A proforma invoice is raised disclosing the ex-showroom price (M.R.P) of the chassis, inclusive of VAT. On receipt of the full consideration (either in part from the financier and the balance from the purchaser and in case of excess payment, refund to the purchaser) a tax invoice is raised making the purchaser (customer) and the financier aware of a discount as set out in a worksheet prepared prior to or simultaneous with the tax invoice. The vehicle is handed over only after the receipt of the price, less the discount from the customer. The