Exemption threshold under sales tax law applies only to notified goods, excluding non-notified purchases from aggregation.

For liability under section 3-D(3) of the U.P. Sales Tax Act, only the turnover of purchases of goods notified under section 3-D(1) is relevant to the exemption threshold. The statutory scheme links both the levy and the threshold to notified goods, and the amendments to the definition of "turnover" did not show an intent to change that basis. Purchases of goods not notified under section 3-D(1) therefore cannot be aggregated with purchases of notified goods when deciding liability under section 3-D(3).

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Issues: Whether, for determining liability under section 3-D(3) of the U.P. Sales Tax Act, the turnover of purchases of goods not notified under section 3-D(1) can be added to the turnover of purchases of notified goods.

Analysis: The relevant scheme of section 3-D showed that the levy and the exemption limit were linked to the turnover of purchases of goods notified under section 3-D(1). The amendments to the definition of "turnover" did not indicate any legislative intent to alter the basis of the exemption limit. The turnover threshold in section 3-D(3) was intended to protect small dealers in respect of notified goods only, and the language of the provision was used in the same sense as in section 3-D(1). Therefore, purchases of goods not notified under section 3-D(1) could not be aggregated with purchases of notified goods for deciding liability under section 3-D(3).

Conclusion: The turnover of non-notified goods cannot be added to the turnover of notified goods for the purpose of section 3-D(3), and the question was answered in favour of the assessee.

Ratio Decidendi: For the exemption threshold under section 3-D(3), only the turnover of purchases of goods notified under section 3-D(1) is relevant, and turnover of non-notified goods is excluded from aggregation.

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