Taxable turnover includes sale-bill surcharges and price equalisation charges; paddy-to-rice conversion also attracts section 5A liability.

Amounts collected from purchasers as administrative surcharge and price equalisation charge were treated as part of taxable turnover under the Kerala General Sales Tax Act because turnover includes the aggregate sale price and sums charged for anything done in respect of the goods sold, and an executive scheme could not alter that statutory character. Dehusking paddy and converting it into rice was also treated as a manufacturing process for section 5A, following binding precedent that the activity attracted the charging provision. On those grounds, the tax levy on the disputed amounts was sustained.

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Issues: (i) Whether amounts collected from purchasers by way of administrative surcharge and price equalisation charge formed part of the taxable turnover under the Kerala General Sales Tax Act. (ii) Whether dehusking paddy and converting it into rice involved a manufacturing process so as to attract liability under section 5A.

Issue (i): Whether amounts collected from purchasers by way of administrative surcharge and price equalisation charge formed part of the taxable turnover under the Kerala General Sales Tax Act.

Analysis: The expression "turnover" covers the aggregate amount for which goods are sold, and the statutory explanation enlarges the concept to include sums charged for anything done by the dealer in respect of the goods sold at or before delivery. The amounts in question were included in the sale bills as part of the price charged to purchasers. A Government executive scheme requiring pass-through of those amounts could not alter the statutory character of the collections for sales tax purposes.

Conclusion: The amounts collected by way of administrative surcharge and price equalisation charge formed part of the taxable turnover and were rightly brought to tax.

Issue (ii): Whether dehusking paddy and converting it into rice involved a manufacturing process so as to attract liability under section 5A.

Analysis: The contention that no manufacturing process was involved was governed by earlier binding authority of the Court, which had already held that the process of converting paddy into rice attracted the charging provision. In view of that settled position, the challenge to the levy under section 5A could not succeed.

Conclusion: The levy under section 5A was upheld.

Final Conclusion: The revision petitions failed on all substantive grounds, and the assessment of the disputed amounts to tax was sustained.

Ratio Decidendi: Amounts collected from purchasers as part of the sale bill constitute part of taxable turnover, and a statutory tax levy cannot be defeated by characterising such collections as amounts payable under an executive scheme.

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