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Issues: Whether turnover tax under section 6B of the Karnataka Sales Tax Act, 1957 had to be computed by applying rule 6(1)(a) of the Karnataka Sales Tax Rules, 1957 so as to exclude purchase turnover of plastic scraps that was otherwise exempt from tax, and whether exemptions granted under notifications issued under section 8A of the Act could prevent levy of turnover tax under section 6B.
Analysis: Section 6B was treated as an independent charging provision levying tax on a dealer's total turnover, and the expression "total turnover" was held to be governed by section 2(u-2) of the Act. The definition of total turnover was considered exhaustive and not dependent upon rule-making for its content. Rule 6 was held to be relevant to the computation of taxable turnover under section 2(u-1), not to the statutory meaning of total turnover for section 6B. The Court also held that subordinate legislation cannot override the parent Act, and that exemptions under other provisions of the Act do not affect the liability under section 6B because that section expressly applies whether or not any part of the turnover is liable to tax under other provisions and prohibits deductions beyond those specifically provided.
Conclusion: Turnover tax under section 6B was validly leviable on the petitioners' total turnover, including the disputed purchases, and the exemptions under the notifications did not exclude that liability.