JUDGEMENT
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(1.) Petitioner-M/s. Natraj Organics Ltd., is engaged in the business of manufacture and sale of sulphuric acid and single superphosphate, which is a chemical fertilizer.
(2.) The question for consideration is that whether the subsidy allowed on fertilizer by the Central Government is liable to be included in the "turnover" as defined in section 2(i) of the U.P. Sales Tax Act, 1948?
(3.) An assessment was made under the Act excluding the subsidy amount from the purview of "turnover", but subsequently the impugned notices under section 21 were issued calling upon the petitioner to show cause why the subsidy amount should not be added to the "turnover" for the years 1985-86 to 1988-89. It is the validity of these notices which is under challenge in this petition.;
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