Assessment year as unit of tax charge means later transactions cannot defeat liability under a last-purchase notification.

Under the General Sales Tax Act, where the assessment year is the unit of charge and a notification fixes the taxable point as the last purchase in the State, liability must be determined only by reference to transactions within that assessment year. Events occurring after the year cannot alter the tax position or defeat the assessment. The expression "last purchase in the State" therefore refers to the last purchase within the relevant assessment period, not to later transactions. On that basis, the assessee could not avoid tax by relying on subsequent purchases or sales, and the challenge to liability failed.

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Issues: Whether, for levy of sales tax under the notification fixing the taxable point as the last purchase in the State, the liability had to be determined only with reference to transactions within the assessment year, so that sales or purchases occurring after that year could not be relied on to defeat the tax.

Analysis: The tax under section 3(1) of the General Sales Tax Act, No. XI of 1125 is levied on the turnover of each year, and section 5(vii) permits the Government to fix a single taxable point by notification. Once the assessment year is treated as the unit of taxation, that year becomes a self-contained period. On that principle, events before or after the year are irrelevant to the assessment. The expression "last purchase in the State" in the notification must therefore be understood as the last purchase within the specified assessment period, and not by reference to later events which may alter the factual position after the year has ended.

Conclusion: The assessee could not escape liability by showing that he was not the last purchaser by reason of subsequent transactions. The taxability had to be determined within the assessment year, and the contention for exemption failed.

Final Conclusion: The revision petition was rejected because the taxable point fixed by the notification operated within the annual assessment unit, and subsequent events could not displace the liability that arose during that year.

Ratio Decidendi: Where a taxing statute makes the assessment year the unit of charge and a notification fixes a single taxable point, liability must be determined with reference to transactions within that year alone, excluding subsequent events.

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