Turnover includes the full agreed sale price for fertilizer mixture; buyer-supplied ingredient value is not deductible.

A contract for supply of fertilizer mixture was held to involve an all-inclusive sale price covering ingredients and manufacturing charges, so the buyer's supply of groundnut oil-cake did not recharacterise the transaction as a works contract or bailment. Under the statutory meaning of sale and turnover, the total amount stated as consideration in the bill of sale formed taxable turnover. The value of the buyer-supplied ingredient could not be deducted, because it was not an ordinary discount within the rules. The entire agreed price of the fertilizer mixture was therefore includible in turnover, and the claimed deduction was not permissible.

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Issues: Whether, on the facts of the contract for supply of fertilizer mixture, the amount to be included in turnover was the full agreed price of the mixture or only the cash balance after deducting the value of groundnut oil-cake supplied by the buyer.

Analysis: The contract, correspondence and bills showed that the parties fixed an all-inclusive price for the completed fertilizer mixture, comprising the cost of ingredients and manufacturing charges. The buyer's supply of groundnut oil-cake did not convert the transaction into a works contract or a bailment arrangement. Under the statutory definitions, sale includes transfer of goods for cash or any other valuable consideration, and turnover means the total amount set out in the bill of sale as consideration. The deduction of the value of the buyer-supplied ingredient did not alter the total consideration for the sale. The claimed deduction could not be treated as a discount within Rule 6(1), since it was not a discount allowed in the ordinary sense contemplated by the rules.

Conclusion: The entire agreed price of the fertilizer mixture formed part of the taxable turnover, and the deduction of the value of groundnut oil-cake was not permissible.

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