Taxable turnover includes local groundnut purchases later sold inter-State; refund provisions do not exclude assessment.

Purchases of groundnuts made within Tamil Nadu and later sold in inter-State transactions were held to remain part of the assessee's taxable turnover under the Tamil Nadu General Sales Tax Act. The statutory provisions were construed together, and section 15 of the Central Sales Tax Act, read with the proviso to section 4 of the State Act, was treated as providing only a later refund mechanism after payment, not as excluding the purchase turnover from assessment in the first instance. The turnover was therefore liable to be included in the taxable turnover under the State Act.

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Issues: Whether the turnover representing purchases of groundnuts within the State, which were subsequently sold in inter-State sales, formed part of the assessee's taxable turnover under the Tamil Nadu General Sales Tax Act despite the provisions of section 15 of the Central Sales Tax Act and the proviso to section 4 of the Tamil Nadu General Sales Tax Act.

Analysis: The disputed turnover arose from purchases made within the State, and the subsequent sales outside the State had already suffered Central sales tax. The statutory scheme was read conjointly, and the Court held that the assessee was bound to include the entire purchase turnover in the taxable turnover under the State Act. The availability of a later refund under section 15(b) of the Central Sales Tax Act read with the proviso to section 4 of the State Act did not exclude the amount from taxable turnover; it only provided a post-payment refund mechanism.

Conclusion: The disputed turnover was held to be part of the taxable turnover and liable to be taxed under the Tamil Nadu General Sales Tax Act.

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