Total turnover governs additional tax under sales tax law; exempt purchase turnover cannot be excluded from the levy base.

For levy of additional tax under section 6-B of the Karnataka Sales Tax Act, the governing measure is the dealer's total turnover, not the narrower taxable turnover. The Court distinguished the two defined concepts, holding that exempt purchase turnover did not cease to form part of total turnover merely because it was exempt from purchase tax under section 6. Reading taxable turnover into section 6-B would substitute one statutory expression for another and contradict the text. The exempt purchase turnover was therefore not excluded in computing the threshold, and the additional tax levy was upheld.

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Issues: Whether, for levy of additional tax under section 6-B of the Karnataka Sales Tax Act, 1957, the exempt turnover of purchases covered by the exemption notification had to be excluded from the dealer's total turnover.

Analysis: Section 6-B was held to operate on a dealer liable to pay tax under section 5 or section 6 whose total turnover reached the prescribed limit. The provision uses the expression "total turnover" and not "taxable turnover". The Court distinguished between the two defined concepts, noting that total turnover is the aggregate turnover of all goods, while taxable turnover is only the turnover remaining after deductions. The exemption from purchase tax under section 6 did not alter the statutory meaning of total turnover for section 6-B. The contention that only taxable turnover could be considered would amount to substituting one defined expression for another, which the language of the provision did not permit.

Conclusion: The exempt purchase turnover was not liable to be excluded while computing total turnover for section 6-B, and the levy of additional tax was upheld in favour of the Revenue.

Final Conclusion: The appeal failed because the statutory basis of the additional levy was the dealer's total turnover, not the narrower taxable turnover, and the order imposing additional tax stood affirmed.

Ratio Decidendi: Where a taxing provision expressly adopts "total turnover" as the measure for an additional levy, that expression cannot be read as "taxable turnover" merely because some component of turnover is exempt from the underlying tax.

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