Contextual interpretation of licence-fee turnover limits fee computation to concession-eligible turnover, not the dealer's entire taxable turnover.

For computing licence fee under the concessional scheme in section 5, turnover must be read contextually as only the turnover covered by the exemption, reduction, or single-point levy, not the dealer's entire taxable turnover. The court reasoned that section 5 and section 6-A make the benefit conditional on obtaining and complying with the licence, while Rule 6's graded fee structure would be undermined if all turnover were included. The licence fee was therefore confined to the portion of turnover eligible for section 5 treatment, and the Revenue's interpretation was accepted.

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Issues: Whether, for computing licence fee under section 5, the relevant turnover includes the dealer's entire turnover or only that part of the turnover to which the concessional or exempt treatment under section 5 applies.

Analysis: Section 5 makes exemption, reduction of tax, and single-point levy subject to prescribed restrictions and conditions, including licences and licence fees. Section 6-A shows that the benefit of section 5 is unavailable unless the licence is taken out and its conditions are observed. Rule 6 prescribes graded licence fees with reference to turnover, but the expression must be read in its context. If the entire turnover were included, the differentiation made by the rule between commodities and the graded scale of fees would lose meaning. The turnover for licence purposes therefore refers only to the part of the dealer's turnover covered by section 5, namely the turnover eligible for total exemption or concessional or single-point taxation, and not the turnover taxable at the normal rate under section 3.

Conclusion: The licence fee is to be computed only on the turnover falling within section 5, not on the dealer's entire turnover. The assessee's contention failed and the Revenue's view was accepted.

Ratio Decidendi: For purposes of a licence fee linked to concessional tax treatment, turnover must be construed contextually as only the turnover covered by the concession, exemption, or single-point levy, and not the dealer's total taxable turnover.

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