Annual sales tax exemption applies for the full financial year when the notification sets no commencement date.

Under a sales tax scheme treated as an annual levy on taxable turnover, an exemption notification without an express commencement date was held to apply to the entire financial year in which it was issued. The Court reasoned that periodic returns and assessments were only machinery for collection, while the statute authorised the Government to declare goods tax-free from time to time without fixing a separate start date for each notification. A later exemption notification therefore governed the relevant year, and the sales tax levy on the exempted goods for that period was unsustainable. The Government could not rely on estoppel against the statute.

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Issues: Whether an exemption notification issued under the sales tax law, without specifying its commencement date, operated only from the date of its issuance or for the whole financial year in which it was issued.

Analysis: The scheme of the Act treated sales tax as a yearly levy on taxable turnover, while the periodic returns and assessments under the rules were only machinery for collection. Section 6 empowered the Government to declare goods tax-free from time to time, but did not itself fix the point of commencement of an exemption. In the absence of an express date in the notification, and since the tax was structured as an annual tax rather than a series of separate quarterly or monthly levies, an exemption granted during the year attached to the whole year. The separate argument based on estoppel against the Government did not avail against the statute, and the later exemption notification governed the tax liability for the relevant year.

Conclusion: The exemption operated for the entire financial year, and the levy of sales tax on the exempted goods for the period in question was not sustainable; the appeal succeeded.

Ratio Decidendi: Where a sales tax statute imposes an annual tax on taxable turnover and an exemption notification does not specify a later commencement date, the exemption takes effect for the whole financial year in which it is granted.

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