Commission agent turnover counts in full for additional sales tax liability under the Tamil Nadu levy.

Under section 2(1)(a) of the Tamil Nadu Additional Sales Tax Act, 1970, a commission agent is treated as a dealer for additional sales tax purposes, and the taxable turnover cannot be split by reference to individual principals. The assessment follows the original sales tax assessment, so the agent's entire turnover is relevant for testing the statutory threshold. On that basis, the note records that agency sales made for Central Government departments remained subject to additional sales tax, even though the assessee earned only commission, and the levy was upheld.

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Issues: Whether an assessee acting as a commission agent for Central Government departments was liable to pay additional sales tax on the turnover of the agency sales, notwithstanding that the principals were Government departments and the assessee earned only commission.

Analysis: Under section 2(1)(a) of the Tamil Nadu Additional Sales Tax Act, 1970, a dealer whose taxable turnover exceeded the statutory limit was liable to additional sales tax. The provision treated a commission agent as a dealer and did not permit a dissection of the turnover into separate transactions of individual principals. The assessment of additional sales tax followed the original sales tax assessment, and the entire turnover of the agent was relevant for determining liability. The reasoning adopted was consistent with the principle that a commission agent remains liable on his whole turnover even when acting for multiple principals.

Conclusion: The assessee was liable for additional sales tax on the agency turnover, and the challenge to the levy failed.

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