Returned goods deduction under sales tax rules is not confined to sales and returns within the same assessment year.

Rule 6(1)(b)(i) of the Andhra Pradesh General Sales Tax Rules, 1957 permits deduction of amounts allowed to purchasers for returned goods when the accounts record the date of return and refund details. The provision contains no express restriction requiring both the sale and return to occur within the same assessment year. In construing a taxing rule, no additional limitation can be implied by equity or convenience, and the dates are required only for verification. The deduction therefore remains available even where the goods were sold in a previous year and returned in the assessment year.

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Issues: Whether deduction under rule 6(1)(b)(i) of the Andhra Pradesh General Sales Tax Rules, 1957, for amounts allowed to purchasers in respect of goods returned, is confined only to goods sold in the assessment year or also extends to goods sold in a previous year and returned with refund in the assessment year.

Analysis: Rule 6(1) requires deduction of the amounts specified in its clauses from the total turnover in determining net turnover, subject only to the conditions stated in the rule. Clause (b)(i) allows deduction of amounts allowed to purchasers in respect of goods returned, when the accounts show the date of return and the date and amount of refund. The language of the rule does not impose any further limitation that the sale and return must both occur within the same assessment year. In taxing statutes, nothing can be read in or implied by equity or convenience, and where the rule-maker intended restrictions, they were capable of being expressed in definite terms. The mention of dates in the accounts is only for verification and not for restricting the deduction to a particular period. Accordingly, the fact that the sales were made in the previous year did not exclude the deduction.

Conclusion: The deduction was allowable even though the goods had been sold in the previous year and returned in the assessment year.

Ratio Decidendi: A taxing provision granting deduction for returned goods must be construed strictly according to its words, and where no temporal restriction is expressed, the deduction cannot be limited by implication to sales and returns occurring within the same assessment year.

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