Annual turnover ceiling for sales tax exemption applies to the full financial year after amendment, defeating exemption once exceeded.

Exemption notifications under the Tamil Nadu General Sales Tax Act are concessional and must be strictly construed, so an amended turnover ceiling applies to the assessment of the entire financial year. Because assessment is made for the full financial year, turnover earned before the amendment cannot be ignored when testing compliance with the revised limit. Once the dealer's total annual turnover of bakery products exceeded the amended ceiling, the exemption could not be allowed for the year. The Revenue's view therefore prevailed, and the exemption orders were set aside with the assessment restored.

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Issues: Whether the exemption for bakery products under the sales tax notification, as amended by the later notification during the assessment year, had to be applied on the basis of the dealer's total turnover for the entire financial year, thereby denying exemption once the annual ceiling was exceeded.

Analysis: The assessment under the Tamil Nadu General Sales Tax Act is made for the entire financial year, and "year" means the financial year. The exemption notifications issued under section 17 grant only a concession, and such notifications must be strictly construed. When the later notification inserted a ceiling that the total turnover of bakery products for a year should not exceed rupees two lakhs, the amended condition governed the assessment for the whole year. The turnover already earned before the amendment could not be ignored, because the levy is determined on the basis of the annual turnover and the exemption does not wipe out the turnover itself.

Conclusion: The exemption was not available for the entire year once the amended turnover limit was applied to the total annual turnover; the Revenue's contention succeeded.

Final Conclusion: The orders granting exemption were set aside and the assessment made by the revenue authorities was restored.

Ratio Decidendi: An exemption notification under the sales tax law, if amended during the assessment year, must be applied to the assessment of the entire financial year, and the exemption cannot survive where the dealer's total annual turnover exceeds the amended ceiling.

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