The main legal point established in the judgment is that the language of exemption notifications should be interpreted in conformity with the definitions and provisions of the relevant Act.

( 1 ) WE are concerned in these Appeals with three exemption notifications issued under the provisions of Section 8a of the karnataka Sales Tax Act, 1957 (for short "the Act' ). The three notifications are in substantially identical terms. The last of them, dated 31 st March 1984, may be reproduced. It reads thus:"in exercise of the powers conferred by Section 8a of the karnataka Sales Tax Act, 1957 (Karnataka Act 25 of 1957) and in supercession of Notification No. FD 51 CSL 83, dated 31st march 1983, the Government of Karnataka hereby reduces with effect from the 1st day of April 1984, the rate of tax payable by a dealer under Section 5 of the said Act on the sale of hand made washing soaps manufactured by him to four per cent provided that the total turnover of any such dealer in a year does not exceed rupees ten lakhs. "

( 2 ) THE question that we have to answer in these Appeals may be put thus: Whether the "total turnover" of a dealer referred to in the notifications means, as the assessees contend, only the turnover in hand made washing soaps or, as the Revenue contends, the total turnover of the dealer in all goods in which he deals including hand-made washing soaps?

( 3 ) THE Authorities below having come to a conclusion in favour of the Revenue, the assessees filed the Writ Petitions. The learned single Judge held that the contention of the assessees was correct and, accordingly, set aside the notices issued to the assessees by the revenue. Hence, these Appeals.

( 4 ) OUR attention was drawn by Mr. H. L. Dattu, learned High Court Government Advocate, appearing for the Revenue, to the provisions of Section 2 (1) (u-2) of the Act which defines "total turnover". Thereunder "total turnover" means the aggregate turnover in all goods of a dealer at all places of business in the State, whether or not the whole or any portion of such turnover is liable to tax, including the turnover of purchase or sale in the course of inter-State trade or commerce or in the course of export of the goods out of the territory of india or in the course of import of the goods into the territory of India" we may also note the definition of "turnover" in Section 2 (v) of the act. It means "the aggregate amount for which goods are bought or sold or supplied or distributed. . . by a dealer, either directly or through another, on his own account or on account of others, whether for cash or deferred payment or other valuable consideration. "

( 5 ) MR. H. L. Dattu submitted that, having regard to the definition of total turnover in the Act the expression in the Notifications issued under the Act should bear the same meaning. In this behalf he relied upon the Judgment of this Court in the case of B. P. AUTOMOBILES and OTHERS vs STATE OF KARNATAKA AND ANOTHER. The provisions of Section 6b (1) of the Act used the expression "total turnover". It was argued that the expression in Section 6b (1) ought not to be read in accord with the definition under Section 2 (1) (u-2 ). The Division Bench, upon consideration of the arguments, came to the conclusion that the contention of the Revenue, namely, that the expression total turnover in Section 6b (1) was required to be read in terms of Section 2 (1) (u-2), had to be upheld. Mr. Dattu also drew our attention to the Decision of a Division Bench of the Bombay High court in COMMISSIONER OF SALES TAX vs RADHA DYEING AND printing MILLS, wherein it was held that, in view of the provisions of the General Clauses Act, where any Act conferred a power to Issue a notification, order, rule or bye-law, an expression used in such notification, order, rule or bye-law ought, unless there was anything repugnant in the subject or context, to bear the same meaning as it bore in the Act conferring the power.

( 6 ) ON behalf of the assessees it was submitted thus: "the expression 'total turnover' as it occurs in the Notifications should be confined to the total turnover of only hand-made washing soaps. Any other const