Concessional sales tax notification under the principal Act does not exempt liability under an independent additional sales tax levy.

A concessional notification under the Tamil Nadu General Sales Tax Act, 1959 did not extend to liability under the Tamil Nadu Additional Sales Tax Act, 1970. The additional sales tax was treated as an independent levy superadded to the principal tax, with its own turnover-based charge and a limited ceiling for declared goods, but no separate exemption or rate reduction flowed from a concession granted only under the principal Act. Accordingly, relief under the principal sales tax notification did not by itself reduce or extinguish liability under the additional sales tax statute.

---

---

Issues: Whether a notification granting concessional rate under the Tamil Nadu General Sales Tax Act, 1959 exempts the dealer from liability to pay additional sales tax under the Tamil Nadu Additional Sales Tax Act, 1970.

Analysis: The notification relied on dealt only with the tax payable under the principal sales tax enactment and did not refer to the additional sales tax statute. The additional sales tax was held to be an independent levy, superadded to the tax payable under the principal Act, with its own turnover-based charge and a limited proviso ensuring that in the case of declared goods the combined burden does not exceed the prescribed ceiling. A concession under the principal Act was therefore held not to extend to exemption or reduction under the additional sales tax law, which contained no separate provision for exemption or rate reduction on that basis.

Conclusion: The concession under the principal Act does not relieve the dealer from liability under the Tamil Nadu Additional Sales Tax Act, 1970, and the writ petitions failed.

Ratio Decidendi: A concessional notification under the principal sales tax enactment does not, by itself, exempt or reduce liability under an independent additional sales tax statute unless the latter statute or the notification expressly so provides.

---