JUDGMENT : The petitioner is aggrieved with Ext.P19 proceedings of the Additional Registering Authority, Cherthala, declining the petitioner's claim for assessment under the Kerala Motor Vehicles Taxation Act, 1976, ('Taxation Act' for short) deeming the purchase value of the vehicle to be Rs.8 lakhs as seen from the sale letter by which the petitioner had purchased the vehicle from the registered owner at Himachal Pradesh. 2. The undisputed facts are that the petitioner purchased a Mitsubishi Pajero Car (LMV) bearing No. HP-72-B-4455 from Himachal Pradesh in the year 2014. The vehicle was one manufactured in the year 2009 and registered in Himachal Pradesh on 05.11.2012. The owner of the vehicle, at the time of registration in Himachal Pradesh, had paid the one time tax, as applicable to that State, which is valid up to 2027, i.e. 15 years. The petitioner having purchased the vehicle in the year 2014, transferred the same to the State of Kerala and sought for registration of the same when demand of tax was made on the basis of the original price of the vehicle, but, making deductions as permissible in the table under Annexure I of the Taxation Act. 3. The petitioner's contention is that the vehicle, which is purchased by the petitioner, being a second hand vehicle, brought into this State from Himachal Pradesh, where it was registered originally, could be levied tax only under the third proviso to sub-section (1) of Section 3 of the Taxation Act. The petitioner asserts that the tax payable would be that specified in Annexure II, which is only Rs.10,600/- for five years. The petitioner also relies on the judgment in the petitioner's case itself, produced at Ext.P1, wherein this Court had considered the issue and having recorded the findings of the petitioner, directed consideration on the basis of the overall factual situation. Immediately it cannot but be noticed that there is no binding declaration made in Ext.P15 judgment. 4. The learned Government Pleader, argues that the third proviso to sub-section (1) of Section 3 of the Taxation Act can have meaning only if there are two comas provided; after the words 'five years' and 'tax has been paid'; without which the proviso itself would be meaningless. 4. The learned Government Pleader, argues that the third proviso to sub-section (1) of Section 3 of the Taxation Act can have meaning only if there are two comas provided; after the words 'five years' and 'tax has been paid'; without which the proviso itself would be meaningless. It is the contention of the learned Government Pleader that the new motor vehicle, as spoken of in the 2nd proviso to Section 3 (1), of the Taxation Act, contemplates a vehicle which is registered for the first time within the State, for which the one time tax is to be paid at the rate specified in Annexure I. Annexure I also takes in the vehicles, like the petitioner's vehicle, which are migrated to the State of Kerala, in which event, there is a deduction offered by way of the table appended to Annexure II. The petitioner's vehicle, having been first registered in 2012, would be entitled to exemption of four years and would have to satisfy the liability of tax which is at 80% of that levied for the newly purchased vehicle. 5. The third proviso to sub-section (1) of Section 3 of the Taxation Act reads as under: "Provided also that in respect of old motor cycles specified in item (1), old three wheelers specified in item (2), and old motor cars specified in item 11 (i) of the schedule, there shall be levied a tax in advance for a period of five years, after the expiry of the period in respect of which tax has been paid, at the rate specified in Annexure II and for new goods carriages specified in item (3)(i)(a) to (3)(i)(e) and (3)(ii)(a) to (3)(ii)(e), new autorickshaws specified in item 7(i)(a), there shall be levied a tax in advance for a period of five years at the rate specified in Annexure II at the time of first registration of the vehicle and there after tax shall be levied for five years or for one year at the rate specified in the seventh proviso to subsection (1) of section 4." This Court is inclined to accept the contention of the learned Government Pleader, since, if the proviso is read without the comas, as provided in the above extract; but not available in the Taxation Act, the proviso itself would be rendered meaningless. The coma so provided is also appropriate in the context of a reading of the entire provision as such. 6. As per the second proviso to sub-section (1) of Section 3 of the Taxation Act, with respect to a new motor vehicle, one time tax is to be levied at the rates specified in Annexure I, at the time of first registration of the vehicle and for those vehicles further tax shall be levied only at the time of renewal of registration or on the expiry of the life time tax already paid. With respect to the old motor vehicles, namely motorcycles, three wheelers and motor cars, there is levied a tax in advance for a period of five years, at the rates specified in Annexure II, after the expiry of the period, for which tax has been paid under Annexure I. Hence, a vehicle which is first registered within the State of Kerala, has to be levied tax at the rates specified in Annexure I and for a further levy of tax, after the expiry of the life time tax or at the time of renewal of registration, tax has to be levied at the rates specified in Annexure II. 7. The contention of the petitioner that the petitioner's vehicle which is first registered within the State has to be levied tax at the rate specified in Annexure II, hence, cannot hold good. The petitioner's vehicle, which is sought to be registered first within the State of Kerala, has to be levied with tax at Annexure I B which is extracted hereunder: "Motor cycles (including motor scooter and cycles with attachments for propelling the same by mechanical power) and three wheelers (including tri cycles and cycle rickshaws with attachments for propelling the same by mechanical power) not used for transport of goods or passengers and private service vehicle for personal use (NTV) and motor cars which were originally registered in other state on or after 1st April 2007 and migrated to Kerala State." 8. The further contention is with respect to the purchase value of the vehicle, which, according to the petitioner, has to be taken from the sale letter, by which the purchase was made by the petitioner. The further contention is with respect to the purchase value of the vehicle, which, according to the petitioner, has to be taken from the sale letter, by which the purchase was made by the petitioner. The definition of 'purchase value' as is seen from the Taxation Act, is as under: "(e) "purchase value" means the value of the vehicle as shown in the purchase invoice and includes value added tax, cess and customs/excise duty chargeable on vehicles: Provided that the discount or rebate given by the dealer to the registered owner shall not be deducted from the bill amount for computing the purchase value: Provided further that where the purchase value of any vehicle including a vehicle imported from other countries or a vehicle acquired or obtained otherwise than by way of purchase is not ascertainable on account of non availability of the invoice, the purchase value shall be the value or price of the vehicles of the same specifications which are already registered or available with the manufacturer or as fixed by the Customs and Central Excise Department for the purpose of levying customs duty and includes excise or customs duty levied on the purchase of a motor vehicle, as the case may be." 9. The purchase value hence means the value of the vehicle as shown in the original purchase invoice, which includes the Value Added Tax, Cess and Customs or Excise Duty chargeable. Hence, the purchase value as indicated in the Taxation Act is that of the vehicle of same specification already registered or available with the manufacturer. It cannot be the value of the subsequent sale, which is at the option of the individuals who sell and purchase the vehicle and that cannot be reckoned for determining the tax under the Act. 10. The interpretation as provided herein above renders the writ petition as one devoid of merit. The petitioner having imported the vehicle from another State, where it was originally registered has to pay tax in accordance with the levy made for such cars brought into the State as per Annexure I-B; read with the Table appended there enabling deduction based on the age of the vehicle from its year of original registration. The purchase value too is the value as seen from the proviso to the definition clause herein above extracted. The purchase value too is the value as seen from the proviso to the definition clause herein above extracted. The conclusion is of the grounds taken being untenable; and the writ petition is liable to be dismissed, I do so, leaving the parties to suffer their respective costs.