Invoice-linked pre-delivery service charges for cylinders are includible in turnover unless a specific deduction is proved.

Cleaning and testing charges collected through the invoice for carbon dioxide cylinders were treated as part of turnover because they formed part of the sale consideration for services done in relation to the goods before delivery. Under the turnover definition, sums charged for anything done by the dealer in respect of goods sold at or before delivery are includible unless the dealer proves a specific deduction under the sales tax rules. As no permissible deduction was established, the charges were assessable to tax and could not be excluded from taxable turnover.

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Issues: Whether cleaning and testing charges collected for cylinders used to supply carbon dioxide formed part of turnover and were taxable under the Kerala General Sales Tax Act, 1963.

Analysis: The charges were collected from customers by including them in the invoice for the sale of carbon dioxide in cylinders. Turnover under section 2(xxvii) means the aggregate amount for which goods are bought or sold, and explanation (2)(i) covers sums charged for anything done by the dealer in respect of the goods sold at the time of or before delivery. The assessee did not establish that the amounts collected were deductible under any of the items in rule 9 of the Kerala General Sales Tax Rules, 1963. As the charges were part of the sale consideration and not shown to fall within any permitted deduction, they were includible in turnover and assessable to tax.

Conclusion: The cleaning and testing charges formed part of turnover and were liable to tax.

Final Conclusion: The revision cases failed, and the assessee was not entitled to exclusion of the cleaning and testing charges from taxable turnover.

Ratio Decidendi: Amounts charged in the sale invoice for services done in relation to goods before delivery form part of turnover, unless the dealer establishes a specific deduction under the sales tax rules.

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