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Issues: Whether inter-State sales could be included in the computation of total turnover for determining the minimum turnover threshold under Section 3 of the General Sales Tax Act, 1959, and whether Rule 6(g) of the General Sales Tax Rules justified such inclusion.
Analysis: Section 3, being the charging provision, fastens liability only on a dealer whose total turnover for the year is not less than the prescribed minimum. The expression "total turnover" must be confined to turnover in local sales or purchases within the State, because the statutory charge itself is limited by the constitutional competence of the taxing authority. Inter-State sales are outside the scope of the local Act and cannot be treated as part of the chargeable turnover merely because the definition of total turnover refers to turnover that may not be liable to tax. That language is directed to sales otherwise chargeable under the Act but exempted from tax, not to transactions wholly beyond the Act. Rule 6(g) operates in the area of deduction or exclusion from taxable turnover and cannot enlarge the charging section.
Conclusion: Inter-State sales could not be added to the assessee's turnover for the purpose of crossing the statutory minimum, and the turnover did not attract tax.
Ratio Decidendi: In computing the minimum turnover threshold under a sales tax charging provision, only transactions within the taxing statute's chargeable field can be counted, and sales wholly outside the statute's competence cannot be included by resort to a deduction rule.