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Issues: Whether G.O. Ms. No. 540 reduced only the basic rate of tax under the Andhra Pradesh General Sales Tax Act, 1957, or whether it limited the total tax liability to 4 per cent so as to exclude additional tax under section 5-A and surcharge under section 6-B.
Analysis: The notification was read as a whole and its reference to reduction of the rate of tax "notwithstanding anything contained in any of the Schedules" was held to point to the basic rate specified in the charging schedule entries, not to the entire tax burden. The absence of any express exemption from additional tax and surcharge, unlike other government orders where such exemptions were specifically granted, was treated as significant. The Court also noted the contemporaneous governmental clarification that the reduction was confined to the basic rate and that additional tax and surcharge remained leviable.
Conclusion: The notification did not cap the total tax at 4 per cent, and additional tax under section 5-A and surcharge under section 6-B were payable in addition to the reduced basic rate.