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Issues: Whether raw bathies purchased from unregistered dealers, though exempt from purchase tax under a notification issued under section 8A of the Karnataka Sales Tax Act, 1957, could still be included in the dealer's total turnover for levy of turnover tax under section 6B of the Karnataka Sales Tax Act, 1957.
Analysis: The expression "total turnover" for section 6B is controlled by the statutory definition in section 2(u-2) of the Karnataka Sales Tax Act, 1957, which covers the aggregate turnover of all goods whether or not any part of it is liable to tax. The Court held that the computation provisions in rule 6 of the Karnataka Sales Tax Rules, 1957 cannot override the Act, and that exemption from purchase tax under section 8A does not exempt the same turnover from inclusion for turnover tax. The statutory language of section 6B, especially the words "whether or not the whole or any portion of such turnover is liable to tax under any other provisions of this Act" and the prohibition against any deduction other than those expressly provided, makes the legislative intent clear.
Conclusion: The purchase turnover of raw bathies was validly included in total turnover for turnover tax under section 6B, and the challenge to the assessment failed.
Ratio Decidendi: For the purpose of turnover tax under section 6B, "total turnover" must be taken in the sense defined by the Act itself, and an exemption from tax under another provision does not exclude that turnover unless the statute expressly provides for such exclusion.