Commodity-specific turnover cap under Entry No. 67 applies only to peas and peas dhall sales, not overall dealer turnover.

The turnover cap under Entry No. 67 of Part B of the Fourth Schedule was confined to sales of peas and peas dhall, including broken, husk and dust thereof, because the entry linked the threshold to that commodity alone rather than to the dealer's overall business turnover. The court relied on the wording of the exemption entry and the structure of the comparable Entry No. 68, which used a separate threshold for another category of goods, to confirm that the limit had to be applied commodity-wise. On that construction, the assessment revision based on aggregate turnover was unsustainable.

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Issues: Whether the threshold limit of Rs. 300 crores under Entry No. 67 of Part B of the Fourth Schedule was to be applied only to sales of peas and peas dhall, or on the dealer's overall turnover.

Analysis: The dispute turned on the proper construction of the exemption entry governing sale of peas and peas dhall including broken, husk and dust thereof. The language of the entry linked the turnover cap to the sale of those goods alone, and not to the dealer's entire business turnover. The comparable structure of Entry No. 68, which prescribed a different threshold for another category of goods, reinforced that the turnover ceiling in Entry No. 67 had to be confined to the commodity covered by that entry. On that construction, the revision of assessment on the footing that the dealer had crossed the limit by reference to overall turnover could not stand.

Conclusion: The threshold limit under Entry No. 67 was confined to sales of peas and peas dhall, and the impugned assessment order was unsustainable.

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