K. L. MANJUNATH, J. ( 1 ) THIS Revision Petition is filed by the assessee under Section 15 Aof the Karnataka Tax on Entry of Goods Act, 1979 (hereinafter referred to as 'kteg Act' for short), being aggrieved by the order of the Karnataka Appellate Tribunal, Bangalore in STANo. 1041/2000 dated 19. 10. 2006, whereunder, the appeal filed by the assessee challenging the orders of the Commissioner of Income Tax (Appeals), bangalore dated 14. 7. 2000 has been confirmed. ( 2 ) THE assessee is engaged in the business of execution of works contract of building bus body on the chassis supplied by its customers. According to the petitioner, the K. S. R. T. C. being one of its customers brought the Chassis to its workshop for the purpose of building body. The petitioner, after constructing the body on the Chassis brought by the K. S. R. T. C. , has delivered the buses to the K. S. R. T. C. and the buses were removed from the workshop of the petitioner by the k. S. R. T. C. through its drivers. ( 3 ) THE Deputy Commissioner of Commercial Taxes, Bangalore called upon the petitioner to pay taxes for the assessment year 1995-96 under the KTEG Act of 1979 on the ground that the Chassis supplied by the K. S. R. T. C. for the purpose of building the body to the petitioner-assessee was liable for tax and such tax has to be paid by the petitioner on the ground that the petitioner has caused entry of goods to the local area. Though an explanation was given by the petitioner, the Assessing Officer has turned down the contentions urged by the petitioner. ( 4 ) BEING aggrieved by the orders of the Deputy Commissioner of Commercial Taxes Bangalore, the petitioner filed an appeal before the Joint Commissioner, who also dismissed the appeal on the ground that the petitioner has caused entry of goods into the local area and liable to pay the entry tax on the ground that the goods were brought into the local area by the petitioner on behalf of K. S. R. T. C. Aggrieved by the concurrent findings of the Deputy Commissioner and the Joint commissioner of Commercial Taxes Bangalore, the assessee preferred an appeal to the KAT which appeal has been dismissed against concurrent findings of these orders. The present revision petition is filed raising the following substantial question of law: whether the authorities were right in holding that the petitioner had caused entry of Chassis on behalf of the k. S. R. T. C. and liable to pay entry tax for causing the entry of Chassis into local area, wherein in fact, the petitioner had not caused the entry of Chassis into the local area? ( 5 ) THE learned counsel for the petitioner contends that all the authorities without considering the fact that the petitioner did not cause any entry of Chassis into the local area and by mis-interpreting the facts, have wrongly called upon the petitioner to pay the entry tax. According to him, the Chassis were purchased by the K. S. R. T. C. and the K. S. R. T. C. brought those Chassis to the premises of the assessee for the purpose of building the body. The petitioner, after building the body has delivered the vehicles to the K. S. R. T. C. and the k. S. R. T. C. has taken possession of the vehicle from the premises of the petitioner assessee and therefore, he contends that the petitioner at no point of time caused entry of Chassis into any local area and that the authorities, by interpreting the provisions of law wrongly, have called upon the petitioner to pay the income tax. According to him, if the authorities have considered the case properly, they would not have called upon the petitioner to pay the tax. Therefore, he contends that by wrong application of law, the petitioner is made to pay the tax and requests this Court to answer the question of law in favour of the assessee. ( 6 ) PER contra, Shri. Gangadhar Sangolli, learned Additional government Advocate relying upon sub-section 2 of Section 3 of kteg Act, 1979 and explanations thereto contends that the petitioner being a dealer on behalf of the K. S. R. T. C. , has caused entry of goods into the local area. Therefore, the petitioner has to pay the tax and the authorities were right in holding that the petitioner was liable to pay the entry tax. ( 7 ) SUB-SECTION (2) of Section 3 of the KTEG Act, 1979 and the explanation thereto reads as hereunder: 3 (2 ). Therefore, the petitioner has to pay the tax and the authorities were right in holding that the petitioner was liable to pay the entry tax. ( 7 ) SUB-SECTION (2) of Section 3 of the KTEG Act, 1979 and the explanation thereto reads as hereunder: 3 (2 ). The tax levied under sub-section (1) shall be paid by every registered dealer or a dealer liable to get himself registered under this Act [or the Central government or a State Government other than the State government of Karnataka] who brings or causes to be brought into a local area the goods whether on his own account or on account of his principal or any other person or who takes delivery or is entitled to take delivery of such goods on its entry into a local area. Explanation: Where the goods are taken delivery of on its entry into a local area or brought into a local area by a person other than a dealer, the dealer who takes delivery of the goods from such person shall be deemed to have brought or caused to have brought the goods into the local area. After careful reading of the provision of law relied upon by the learned Government Advocate, we would have appreciated the contention of the State, provided the petitioner had brought the Chassis into the local area on behalf of the. K. S. R. T. C. On facts, the petitioner has not caused any entry of the Chassis into the local area either for the use of the assessee or for the benefit of the K. S. R. T. C. The State has not disputed the fact that the Chassis was purchased by K. S. R. T. C. and the petitioner assessee has only built the body for the benefit of the K. S. R. T. C. Therefore, what is required to be considered by us in this case, is whether the Chassis is brought into the local area by the petitioner on behalf of K. S. R. T. C. to call upon the petitioner to pay the tax. If the petitioner or its employees have caused entry of Chassis into the local area, then the authorities could have demanded the petitioner to pay the tax in view of the explanation to sub-section (2)of Section 3 of the Act. If the petitioner or its employees have caused entry of Chassis into the local area, then the authorities could have demanded the petitioner to pay the tax in view of the explanation to sub-section (2)of Section 3 of the Act. But on facts, it is the specific contention of the petitioner that the Chassis was supplied by the K. S. R. T. C. to him and the body was built by the petitioner in its workshop and after building the body, the buses were taken by the K. S. R. T. C. from the premises of the petitioner. Therefore, the question would be whether such transaction could be held that the petitioner has caused entry of goods into the local area. If the petitioner has not done anything except building the body on the Chassis supplied by the K. S. R. T. C. within its premises, we are of the opinion that sub-section (2) of Section 3 of the Act and the explanation thereto does not attract the petitioner to pay tax since he has not caused any entry of goods to the local area. The authorities by mis-appreciation of the facts of the case, have wrongly called upon the petitioner to pay the tax. ( 8 ) IN the circumstances, we answer the question of law raised in this petition in favour of the assessee and allow the petition and set aside the order of the Assessing Officer dated 24. 6. 1999 and the order passed by the Joint Commissioner of Commercial Taxes, bangalore dated 14. 7. 2000 and the order passed by the Karnataka appellate Tribunal dated 19. 10. 2006 in STANO. 1041/2001. If any amount is paid by the petitioner towards tax, he is entitled to seek for refund of the amount from the respondent.