Plain-language exemption turnover limits apply to the assessee's entire turnover unless the notification expressly excludes exempt sales.

Where an exemption notification uses plain and unambiguous language to cap eligibility by turnover, the prescribed limit applies to the assessee's entire turnover unless the notification itself excludes exempt sales. The Allahabad HC held that turnover not liable to tax under other provisions could not be excluded from the computation, because the clause made no distinction between taxable and non-taxable turnover. The factual inability to maintain separate accounts also supported treating turnover as indivisible on the facts. The Tribunal's view was therefore not disturbed and the challenge failed.

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Issues: Whether, for the purpose of the turnover limit of exemption under the notification dated 27.02.1997, the assessee's entire turnover was to be taken into account or only the taxable turnover.

Analysis: The notification granted exemption up to a specified turnover to institutions registered with the U.P. Khadi Gramodyog Board, and the relevant clause was read on its plain language. The clause did not distinguish between taxable turnover and turnover not liable to tax under other provisions of the Act. On a simple reading, the turnover limit was held to refer to the entire turnover of the assessee, and not merely to the portion on which tax was payable. The inability to maintain separate accounts for the different categories of purchases and sales also supported the conclusion that segregation of turnover was not possible on the facts.

Conclusion: The entire turnover of the assessee had to be considered for computing the exemption limit, including turnover not liable to tax under other provisions. The challenge to the Tribunal's order failed.

Ratio Decidendi: Where the language of an exemption notification is plain and unambiguous, the turnover limit prescribed by it must be applied to the assessee's entire turnover, without excluding sales already exempt from tax under other provisions, unless the notification itself makes such exclusion.

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