Cattle feed exemption and post-sale administrative charges were excluded from taxable turnover under sales tax law.

Wheat bran and bran flakes qualified for sales tax exemption as cattle feed under the exemption notification, because the notification covered the commodity as such and did not require exclusive use as cattle feed; the possibility of other uses did not defeat the exemption. Bran flakes were treated as another form of wheat bran and received the same exemption. Administrative charges shown separately in sale bills were not includible in taxable turnover, as they were fixed by the Government, collected only for remittance to the Civil Supplies Department, and constituted reimbursable post-sale charges rather than part of the sale price.

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Issues: (i) Whether wheat bran and bran flakes were exempt from sales tax under the exemption notification issued under section 17(1) of the Tamil Nadu General Sales Tax Act, 1959 as cattle feed; and (ii) whether amounts shown separately as administrative charges in the sale bills were includible in taxable turnover.

Issue (i): Whether wheat bran and bran flakes were exempt from sales tax under the exemption notification issued under section 17(1) of the Tamil Nadu General Sales Tax Act, 1959 as cattle feed.

Analysis: The notification, as amended, specifically covered cattle feed including rice bran and wheat bran. The Court held that wheat bran was accepted as cattle feed and that the notification did not impose any condition that the sale must be only as cattle feed for exemption to apply. The possibility of some other use, such as oil extraction or poultry feed, did not justify denial of exemption. The later amendment omitting the words "cattle feed" also supported the broader exemption. Bran flakes were treated as only another form of wheat bran and, on the same reasoning, fell within the exemption.

Conclusion: The exemption applied to wheat bran and also to bran flakes; the Revenue's denial of exemption was unsustainable.

Issue (ii): Whether amounts shown separately as administrative charges in the sale bills were includible in taxable turnover.

Analysis: The charges were fixed by the Government and collected by the flour mills only to be remitted to the Civil Supplies Department. They were shown separately as reimbursement for services rendered and were treated as post-sale charges. Since the mills acted merely as collecting agents and the amounts were not part of the price of the goods, they could not be included in the taxable turnover.

Conclusion: Administrative charges were not includible in taxable turnover.

Final Conclusion: The appeals succeeded in full, and the revisions made by the Revenue were set aside.

Ratio Decidendi: Where an exemption notification covers a commodity as such and does not impose a user-based condition, the exemption cannot be denied merely because the commodity may have other possible uses; likewise, amounts collected only as reimbursable post-sale charges and passed on to a third party do not form part of taxable turnover.

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