Total turnover under exemption notifications means aggregate dealer turnover, not just soap turnover, where statutory definition applies.

An exemption notification under section 8-A of the Karnataka Sales Tax Act used the expression "total turnover" as a condition for concessional tax on handmade washing soaps. The statutory definition in section 2(1)(u-2) treated total turnover as the dealer's aggregate turnover in all goods, and the notification gave no contextual basis to narrow it to soap sales alone. The expression was therefore given its statutory meaning, because a restricted reading would render "total" ineffective. The concession could validly be made subject to the dealer's overall turnover ceiling, and the narrower construction was rejected.

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Issues: Whether, for the exemption notifications issued under section 8-A of the Karnataka Sales Tax Act, 1957, the expression "total turnover" meant only the turnover of handmade washing soaps or the dealer's aggregate turnover in all goods.

Analysis: The notifications granted a reduced rate of tax on sales of handmade washing soaps subject to the condition that the dealer's total turnover in a year did not exceed the stipulated limit. The statutory definition of "total turnover" in section 2(1)(u-2) covered the aggregate turnover in all goods of a dealer, and section 2(1)(v) defined "turnover" broadly. The Court held that the notification language was clear and that there was no contextual basis to restrict "total turnover" to handmade washing soaps alone. A restricted reading would render the word "total" ineffective, and the power under section 8-A permitted the Government to impose the turnover ceiling as a condition for the concession.

Conclusion: "Total turnover" in the notifications meant the dealer's aggregate turnover in all goods, not merely the turnover of handmade washing soaps, and the assessees were not entitled to the restricted construction.

Ratio Decidendi: Where an exemption notification uses an expression that is also defined in the parent Act, and the notification contains no contextual indication to depart from that definition, the expression must be given its statutory meaning and cannot be narrowly confined so as to make part of the language otiose.

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