RAJAGOPALAN, J.

These are petitions under section 12-B of the Madras General Sales Tax Act to revise the orders of the Appellate Tribunal.

The respondents were dealers in motor cars and their accessories. On the turnover of the sales of those goods, they were liable to pay sales tax at the standard rate of Rs. 0-0-3 in the rupee, prescribed by section 3(1)(b) of the Act. In addition they were liable to pay tax at the rate of Rs. 0-0-6 in the rupee under section 3(2)(iv) of the Act. The assessing authorities included in the taxable turnover of each of these dealers amounts collected by them by way of tax under section 8-B of the Act and assessed that part of their total turnover also at the rate of Rs. 0-0-9 in the rupee. In Krishnaswami Mudaliar's case this Court held that the turnover made up of amounts collected by way of tax by a registered dealer could not be assessed at all to any tax under the Act. Subsequent to that, the Madras Legislature enacted Act XVII of 1954 to validate the levy of tax on amounts collected by a dealer by way of tax. The validity of that Act has been upheld by us in Sundararajan and Co., Ltd. v. State of Madras and that has been reiterated by us in T.R.C. Nos. 46 etc. of 1955 in which we have just delivered judgment.

The only question that remains for determination in these cases is whether the Tribunal was right in the view it took that amounts collected by way of tax and deemed to be part of the turnover of a dealer under section 2 of Act XVII of 1954 were liable to be assessed only under section 3(1)(b) of the Sales Tax Act and that it would not be subject to the additional tax authorised by section 3(2)(iv) of the Act.The tax authorised by section 3(1) of the Act is on the total turnover of a dealer; see section 3(1)(b). The additional tax authorised by section 3(2) of the Act is among others on the first sale of the goods mentioned in section 3(2)(iv); and section 3(2) directed that the additional levy shall be in addition to the tax, to which the dealer seller is liable under sub-section (1) on his total turnover for the year. Section 2 of Act XVII of 1954 runs :

"In the case of sales made by a dealer before the 1st April, 1954, amounts collected by him by way of tax under the Madras General Sales Tax Act, 1939 ....... shall be deemed to have formed part of his turnover".

"Turnover" has been defined by section 2(1) of the Act. "Turnover" means the aggregate amount for which goods are either bought by or sold by a dealer ........ for ....... valuable consideration. The expression "sale" has been defined in section 2(h) of the Act. It is with reference to these provisions, that we have to answer the question at issue, whether the amounts collected by way of tax by a dealer on the sale of goods that fell within the scope of section 3(2)(iv) of the Act are liable to pay the additional tax under section 3(2)(iv) of the Act.

The Tribunal recorded,

"tax collected by the dealer becomes part of his total turnover by reason of the Validation Act, and it follows that it will be subject only to the three pies rate under section 3(1)(b)." *

That the amounts collected by the dealer by way of tax became part of his turnover under section 2 of Act XVII of 1954 does not admit of any controversy at this state. That is was part of the total turnover within the meaning of section 3(1)(a) should also be beyond dispute. It should follow that on that turnover also the dealer is liable to pay the tax prescribed by section 3(1)(b). But the question still remains, is the dealer also liable to pay the additional tax prescribed by section 3(2)(iv).As we pointed out, what section 3(2)(iv) authorises is the levy of the additional tax of Rs. 0-0-6 on the sale of any of the goods mentioned therein. What did the amounts collected by the dealer by way of tax under the authority of section 8-B of the Act represent ? In Sundararajan and Co., Ltd. v. State of Madras we pointed out that the amounts collected by way of tax u