Charging provisions must be construed strictly: Karnataka additional tax could not extend to inter-State sales taxed under CST.

Section 6-B of the Karnataka Sales Tax Act, 1957, as then in force, operated as a charging provision only for sales or purchases taxed under that Act and did not extend to inter-State sales assessed under the Central Sales Tax Act, 1956. The proviso concerning declared goods limited the rate where the levy otherwise applied, but did not enlarge the charging field. Section 8 of the Central Sales Tax Act regulates the rate of tax on inter-State sales and does not itself authorise a State additional levy. Accordingly, additional tax under section 6-B could not be imposed on such turnover, and related notices were without jurisdiction.

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Issues: Whether additional tax under section 6-B of the Karnataka Sales Tax Act, 1957 could be levied on inter-State sales and declared goods assessed under the Central Sales Tax Act, 1956, and whether section 8 of the Central Sales Tax Act, 1956 authorised such levy.

Analysis: Section 6-B, as it stood during the relevant period, was a charging provision imposing an additional levy only on sales or purchases brought to tax under the Karnataka Sales Tax Act. A charging section is to be construed strictly, and nothing in section 6-B indicated an intention to extend the levy to inter-State sales taxed under the Central Sales Tax Act. The proviso dealing with declared goods limited the rate of levy where the provision otherwise applied, but it did not enlarge the charging field to cover inter-State transactions. Section 8 of the Central Sales Tax Act merely regulates the rate of tax on inter-State sales and is not itself a charging provision; it also does not incorporate or authorise levy of a State additional tax such as section 6-B. The authorities relied upon for the Revenue were distinguished because they concerned provisions that expressly enhanced or imposed additional tax on the relevant turnover, unlike section 6-B in its earlier form.

Conclusion: Additional tax under section 6-B of the Karnataka Sales Tax Act, 1957 could not be levied on inter-State sales or declared goods taxed under the Central Sales Tax Act, 1956, and the impugned notices to that extent were without jurisdiction and liable to be quashed.

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