Taxable turnover includes beer bottles and crates where commercial facts show a sale, not a true bailment.

Bottles and crates supplied with beer were treated as part of the taxable turnover because the surrounding commercial facts showed a sale rather than a true bailment. The security deposit, absence of supporting verification from the books, and the practical manner in which the transactions were carried out indicated that customers did not merely hold the receptacles temporarily for return. The later return of bottles and crates was treated as a separate subsequent transaction in favour of the company, not as evidence that ownership had remained with it. The assessee's claim that the containers were only refundable-property arrangements was rejected.

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Issues: Whether the bottles and crates supplied along with beer were sold to the customers so as to form part of the taxable turnover, or whether they remained the company's property and were merely subject to a refundable security arrangement.

Analysis: The company's scheme was examined against the surrounding commercial facts and the conduct of the parties. The authorities and the Court found that the bottles and crates were not kept under any true bailment arrangement and that there was no enforceable obligation showing that the customers merely held them temporarily for return. The security deposits, the absence of supporting verification from the books, and the practical manner in which the transactions were carried out showed that the receptacles passed with the beer. The return of bottles and crates was treated in law as a separate subsequent transaction by the customer in favour of the company, not as proof that ownership had remained with the company.

Conclusion: The bottles and crates were sold along with the beer, and the assessee's contention that ownership remained with it was rejected.

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