JUDGMENT M. P. CHANDRAKANTHARAJ URS, J. - This sales tax revision petition is by the Karnataka Food & Civil Supplies Corporation. Its status is that of a public limited company. For the assessment year 1976-77, i.e., from July 1, 1976 to June 30, 1977, the assessee-company returned taxable turnover at Rs. 18,54,76,058 against a total turnover of Rs. 26,78,68,758. The assessee-company further claimed exemption/deduction in a sum of Rs. 8,23,92,700 comprised under the following heads : 1. Karnataka sales tax collected Rs. 65,31,013.00 2. Sugar and paddy Rs. 1,32,80,374.00 3. Second sales of foodgrains Rs. 4,62,96,511.00 4. Government administrative charges due to Government wholesale commission of the Corporation including the sales for accounting convenience but not taxable as they are not provided for in the costing sheet approved by Government. Rs. 1,62,84,802.00 -------------------- Total Rs. 8,23,92,700.00 -------------------- 2. The assessing authority, while allowing the exemption claimed under the first three heads, declined to allow the exemption claimed under the fourth head, namely, administrative charges incurred. He recorded the reasons for disallowing the claim on the turnover of Rs. 1,62,84,802 in paragraph 5 of the assessment order dated May 26, 1978. 3. We may briefly state the facts. They are as follows : The assessee-company did not produce the sales invoices for inspection of the assessing authority. The administrative charges were deducted from out of the sale prices collected from the purchasers. Such collection was credited to the account of the Government separately as administrative charges. That was so done as a measure of convenience, as explained by the representative of the company. The assessing authority disallowed such a claim on the ground that that deduction was not permissible in accordance with the provisions made in rule 6 of the Karnataka Sales Tax Rules, 1957 for computation or taxable turnover, though he did not record a finding as is evident from the concluding paragraph of the order that administrative charges formed part of the sale prices. Against such disallowance, the assessee-company filed an appeal before the Deputy Commissioner of Commercial Taxes (Appeals). On a further appeal to the Appellate Tribunal in Sales Tax Appeals Nos. 322/84 and 323/84, the contention advanced for the company that administrative charges collected for the company that administrative charges collected under the directions of the Government were liable for exemption, was rejected. On a further appeal to the Appellate Tribunal in Sales Tax Appeals Nos. 322/84 and 323/84, the contention advanced for the company that administrative charges collected for the company that administrative charges collected under the directions of the Government were liable for exemption, was rejected. Therefore, the present revision petition raising the question, whether the administrative charges collected by the assessee-company could be claimed as an exemption. 4. Normally this Court would have no hesitation to state that the assessee-company would be entitled to claim that as an amount which could not be included in the sales or purchase turnover if it did not form part of the sale or purchase prices. Unfortunately, even according to Mr. Nagananda, who produced what he called the costing sheet of the corporation, which, among other things, secures foodgrains from various sources including growers and distributes it to different agencies, public as well as private, for distribution throughout the State and sometimes outside the State, we see with reference to purchase of paddy, the price per quintal is fixed at Rs. 74 for the financial year 1976 commencing from April 1, 1976. Transport charges to grower for delivery is included, making the price payable to the grower at Rs. 80. Thereafter service charges to society/sub-agent who procures on behalf of the corporation apparently is also added to the price. Then interest charges of the assessee-company itself, probably meaning thereby the interest paid by them on the capital borrowed from different sources, a sum of Rs. 6.58 is added. Thereafterwards administrative charges of the assessee-company at Rs. 1.75 is added. Thereafterwards some deduction is given to the quantity on account of dryage and price payable to the assessee-company is arrived at Rs. 140.93. In other words, what is obvious in the costing method is, the establishment charges of the assessee-company per quintal is termed and styled as administrative charges. Therefore, the sale price arrived at in the manner evidenced by the costing sheet is inclusive of administrative charges. But Mr. Nagananda contended that the sum of Rs. 1,62,84,802 claimed as exempted turnover or exemptable turnover related to administrative charges collected on instructions issued by the Government by a particular circular at Rs. 2 per quintal. This was also added to the selling price which became part of the total turnover. But by deducting these administrative charges at Rs. But Mr. Nagananda contended that the sum of Rs. 1,62,84,802 claimed as exempted turnover or exemptable turnover related to administrative charges collected on instructions issued by the Government by a particular circular at Rs. 2 per quintal. This was also added to the selling price which became part of the total turnover. But by deducting these administrative charges at Rs. 2 per quintal as instructed by the Government out of the total turnover, the same was credited to the account of the Government in the books. It was on that basis that the assessee-company claimed exemption. 5. In the absence of invoices of sales, which admittedly were not produced before the assessing authority, there was no way by which the assessing authority could come to the conclusion, whether that formed the sale price on which the tax was collected or not. Separation of the amount in the books of the company would not disclose that fact. It was in that circumstances that he came to the conclusion that it was not liable for exemption, as rule 6 of the Karnataka Sales Tax Rules, which provided for the method of computation of taxable turnover, did not include such a deduction as an item to be exempted from taxable turnover. 6. The terms "turnover", "total turnover" and "taxable turnover" are defined terms. Taxable turnover is the one which is computed in accordance with rule 6 after allowing all permissible deductions. If rule 6 does not provide for a deduction, then it cannot be taken out of total turnover. Therefore, the assessing authority was bound by the rule and notwithstanding the explanation, he could not allow such a deduction, though in fact the assessee-company had credited it to the account of the Government. 7. We cannot find fault with the assessing authority for that. If the assessee-company was not careful enough in preparing its invoices or bills of sale showing its selling price and the tax collected thereon and the administrative charges collected separately, the assessing authority would be free to assume that the tax was collected on the sale price unless it was demonstrable otherwise. But it could not be said that it was demonstrated by crediting the amount of Rs. 2 per quintal in the books of account to the credit of the Government. It could have been demonstrated only by production of the invoices. But it could not be said that it was demonstrated by crediting the amount of Rs. 2 per quintal in the books of account to the credit of the Government. It could have been demonstrated only by production of the invoices. In the absence of it, the assessing authority correctly, following rule 6 of the Karnataka Sales Tax Rules and the provisions thereunder, brought to tax what could not be exempted. The orders upholding such an assessment by the appellate authority and the Tribunal cannot be interfered with by us. 8. The question, whether the turnover relating to transaction of the assessee-company as agent of the Government is liable for exemption, was not raised as such before the assessing authority. Therefore, the question of permitting the assessee-company to raise that question before us is impermissible. Therefore, we do not have to decide that question. 9. The petition is dismissed, but there will be no costs. Petition dismissed.