Annual sales tax exemption applies for the whole assessment year when no later start date is specified.

Under an annual sales tax regime, an exemption notification issued during the assessment year applies to the entire year unless the statute or notification fixes a later commencement date. Because the Andhra Pradesh General Sales Tax Act treats the year as the twelve months ending on 31 March, the assessment could not be split to deny exemption for turnover earned before the notification's publication. The exemption therefore operated from the start of the assessment year, and the relevant turnover remained outside tax for the whole year.

---

---

Issues: Whether an exemption granted by G.O. Ms. No. 116 dated 8th February, 1989 under section 9(1) of the Andhra Pradesh General Sales Tax Act, 1957 operated only from the date of publication or extended to the entire assessment year.

Analysis: Sales tax under the Act is an annual levy and the taxable liability is worked out with reference to the turnover of the full year. Section 2(u) defines "year" as the twelve months ending on 31st March. Where an exemption notification is issued during the assessment year and neither the Act nor the notification specifies a later commencement date, the assessment cannot be split into parts for denying the exemption for the earlier portion of the year. The governing principle is that an exemption coming into force during the year enures for the whole year unless the statute or the notification indicates otherwise.

Conclusion: The exemption applied to the entire assessment year commencing on 1st April and ending on 31st March, and not merely from 8th February, 1989 onwards.

Final Conclusion: The turnover covered by the exemption notification was not taxable for the whole assessment year, so the references failed and the petitions were dismissed.

Ratio Decidendi: In an annual sales tax regime, an exemption notification issued during the assessment year, without a specified commencement date or statutory restriction, operates for the whole assessment year.

---