JUDGMENT M. M. PAREED PILLAY, J. - Appellants challenge the judgment in O.P. Nos. 14991, 15020, 15021 and 16931 of 1992, O.P. Nos. 6743 and 6744 of 1993 and O.P. No. 3430 of 1994. The learned single Judge held that the assessments in question in so far as they impose tax on the amount of subsidy are illegal and unsustainable. Accordingly the writ petitions were allowed and exhibit P4 in O.P. Nos. 14991, 15020 and 15021 of 1992, exhibit P3 in O.P. Nos. 6743 and 6744 of 1993, exhibits P1 to P3 in O.P. No. 16931 of 1992 and exhibits P1, P4 and P7 in O.P. No. 3430 of 1994 to the extent tax is levied on the amount of subsidy were quashed. Though assessments in O.P. Nos. 16931 of 1992 and 3430 of 1994 were taken up in appeal under section 34 of the Kerala General Sales Tax Act, the learned single Judge held that it is not necessary to relegate the parties to the appellate remedy in view of the finding that the amount of subsidy is not part of the taxable turnover of the respondents. 2. The contention of the appellants is that the learned single Judge ought to have accepted the plea of the appellants that the payment of subsidy was with reference to the event of sale and as the price collected from the purchaser kept in view of the pre-concluded promise from the Government of India that in addition to the purchase price paid by the purchaser the seller would get a further sum from the Government "the consumer price support subsidy" ought to have been taken into consideration when the sales turnover of the respondents was determined for the purpose of assessing sales tax. It is further contended that the learned single Judge went wrong in understanding the consumer price support subsidy as "subisdy" as understood in common parlance. The learned Government Pleader argued that in the circumstances of the case the consumer price support subsidy ought to have been taken as part of the sale consideration and the attempt of the learned single Judge in attributing the dictionary meaning of the word "subsidy" has led to the rejection of the contention of the appellants. The learned Government Pleader argued that in the circumstances of the case the consumer price support subsidy ought to have been taken as part of the sale consideration and the attempt of the learned single Judge in attributing the dictionary meaning of the word "subsidy" has led to the rejection of the contention of the appellants. Learned counsel for the respondents submitted that the learned single Judge has considered the matter in its correct perspective and no interference is warranted against the well considered judgment in the writ petitions. 3. The facts in O.P. No. 14991 of 1992 which are typical of the controversy in all the cases were considered by the learned single Judge. The petitioner in O.P. No. 14991 of 1992 is a manufacturer and seller of urea and other complex fertilisers which are essential commodities within the meaning of the Essential Commodities Act, 1955. The Fertilizer (Control) Order, 1985, which repealed and replaced a similar earlier order of 1957, regulates the sale and distribution of fertilisers. Sub-clause (1) of clause 3 which is in Part II of the order relating to the price control, authorities the Central Government to fix the maximum prices or rates at which any fertiliser may be sold by a dealer, manufacturer or a pool handling agency. This is done by notification in the official gazette. The object behind it is to regulate the equitable distribution of fertilisers and making it available at fair price. Sub-clause (2) authorises the Central Government to fix different prices or rates for fertilisers having different periods of storage or for different areas or different classes of consumers, having regard to the local conditions of any area, the period of storage of fertilisers and other relevant circumstances. Sub-clause (3) prohibits the dealer, manufacturer or pool handling agency from selling or offering for sale any fertiliser at a price exceeding the maximum price or rate fixed under this clause. The respondents are governed by this order. They can sell fertilisers pegged to the maximum price fixed by the Central Government. 4. The Central Government's scheme for retention prices was introduced with a view to ensure a reasonable return on investment and to facilitate the healthy development and growth of the fertiliser industry. A substantial contribution was made from Government of India for the purpose of the scheme. 4. The Central Government's scheme for retention prices was introduced with a view to ensure a reasonable return on investment and to facilitate the healthy development and growth of the fertiliser industry. A substantial contribution was made from Government of India for the purpose of the scheme. The scheme provided for an ex-factory retention price per tonne of urea, net of excise duty and Fertilizer Pool Equalisation Charge (FPEC) and exclusive of the approved dealer's margin and equated freight for each plant, based on a capacity utilisation of 80 per cent and a combination of norms and actuals in regard to consumption efficiencies and maintenance and other costs and providing for a post-tax return of 12 per cent of net worth. The scheme was intended to ensure that all units receive the transfer price either through adjustment of the excise duty and FPEC or through alternative means. The units whose retention price as fixed under the scheme was lower than the transfer price were required to credit the difference to the Fund Account. The amount will be calculated on the quantities of fertiliser cleared through excise in any given month from November 1, 1997. It was the amount so received from the Fund Account, constituted and administered by the Central Government, which was in the nature of a subsidy paid to the respondents, that was brought to tax under the Kerala General Sales Tax Act as part of their taxable turnover of the fertilisers. 5. The respondents objected to the inclusion of the amount in their taxable turnover contending that the amount received which is in the nature of subsidy is not taxable. The assessing authority overruled the said objection and completed the assessments levying tax on the amount of subsidy as well. 6. The learned Government Pleader contended that the respondents who have in fact received subsidy amount and the sale price amount from the consumer cannot escape from tax liability. It is argued by him that when the goods are sold the respondents get the sale price and subsidy amount and as the latter amount is closely connected with the actual amount received on each sale the sales turnover would take in the entire amount and hence the entire amount is exigible to tax. It is argued by him that when the goods are sold the respondents get the sale price and subsidy amount and as the latter amount is closely connected with the actual amount received on each sale the sales turnover would take in the entire amount and hence the entire amount is exigible to tax. The respondents relying on Fertiliser Corporation of India Ltd. v. Commercial Tax Officer [1991] 83 STC 129 (AP) and Coromandel Fertilisers Ltd. v. Commercial Tax Officer [1992] 85 STC 552 (AP) contended that they have not received any amount from the purchaser or on his behalf in connection with any sale transaction more than the sale price and so the subsidy amount received by them from the Central Government under the scheme cannot be added to the sale price for the purpose of taxation. The Andhra Pradesh High Court held that the subsidy received cannot be treated as part of the taxable turnover of the assessees as defined in the Andhra Pradesh Act. The learned Government Pleader submitted that the definition of the "turnover" in the Andhra Pradesh Act is different from that contained in the Kerala Act and so the High Court decision of Andhra Pradesh cannot have any application to the case in hand. In Coromandel's case [1992] 85 STC 552 (AP) which arose under the Central Sales Tax Act the definitions concerned were of "sale price", namely, the amount payable to the dealer as consideration for the sale of goods and of "turnover" which meant the aggregate of the sale prices received. From the definition of the word "turnover" in the Kerala Act, it is not possible to distinguish the Andhra Pradesh High Court's decision as sought by the learned Government Pleader. The learned single Judge was justified in holding that the aforesaid decisions are directly in point and cover the cases in favour of the respondents. On going through the decisions, we also agree with the said view. 7. The learned single Judge held that as the sale is not conditional on the Central Government paying any amount by way of subsidy and as there is no agreement between the parties for any further amount to be paid than what was paid by the purchaser at the time of the sale, "turnover" as defined in section 2(xxvii) of the Kerala General Sales Tax Act cannot take in the subsidy amount. The finding of the learned single Judge that the amount of subsidy received by the respondents for the purpose of their units, which is not related to any particular transaction of sale, but is related to other circumstances, cannot constitute turnover in their hands assessable under the Kerala General Sales Tax Act does not warrant interference. We do not see any merit in the writ appeals. The writ appeals are dismissed. Writ appeals dismissed.