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Issues: Whether, in a printing job-work contract where paper is supplied by the printer, the receipts represent taxable turnover in full or whether the labour component is deductible and only the paper cost is assessable.
Analysis: The receipts from the printing work comprised two distinct elements, namely the cost of paper and the charges for labour and printing. The statutory explanation to the definition of turnover covered sums charged for work done in respect of goods sold, but that provision did not apply where the printer was not selling goods belonging to him. In the case of printing judgments or similar work, the printer supplies paper and labour, but the printed product is not a sale of goods by him. The labour component is therefore not chargeable, though the paper cost remains part of the taxable turnover.
Conclusion: The assessment could not be sustained to the extent it included printing charges. The petitioner succeeded, and the respondent was directed to reassess the taxable turnover after excluding labour charges and including only the cost of paper.
Ratio Decidendi: In a printing job-work arrangement, labour charges do not form part of taxable turnover as they do not represent consideration for a sale of goods, while the cost of paper supplied remains taxable.