Judgment :- Mohammed J. This tax revision petitioner is a registered dealer in printing ink under the provisions of the Kerala General Sales tax Act, 1963 (for short 'the act) on the file of the Additional Sales Tax Officer-I, I Circle, Ernakulam. For the assessment year 1991-'92, the dealer filed return showing the total and taxable turnover as Rs. 29,84,110.50 and Rs. Nil respectively. During the said assessment year, the Intelligence Officer, Ernakulam had inspected the business premises of the petitioner on 12.1.1993. From the cross verification of the accounts made after the inspection, the Intelligence Officer found that the sale effected to the Mathrubhoomi daily during the year 1991-92 to an amount of Rs. 6,53,880.25 were not duly accounted in the regular books of accounts. When this defect was brought to the notice of the dealer it admitted the irregularity of non-accounting the aforesaid sales to Mathrubhoomi daily. Thereafter the dealer moved for compounding of the offence department ally. As per the request made by the dealer on 31.3.1993, the offence was compounded on payment of Rs. 39,233.00. For this and various other reasons the return furnished by the dealer was rejected by the assessing authority and assessment was completed on best of judgment as proposed in the pre-assessment notice. As against the said assessment order the petitioner filed an appeal before the appellate Assistant Commissioner, Ernakulam. A specific contention was urged in the appeal mat the offence was compounded on payment of Rs. 39,233.00 under S.47(1) (a) and the amount paid as compounding fee was not adjusted towards the tax due. This contention was rejected by the Additional appellate Assistant Commissioner and the assessment passed by the sales tax officer was confirmed. The matter was again taken up in further appeal before the Sales Tax appellate Tribunal. The appellate Tribubal while dealing with the question of composition of offence observed that the amount paid as compounding fee cannot be deducted from the sales tax payable by the dealer. This revision petition has been filed by the dealer against the said order passed by the tribunal. 2. The appellate Tribubal while dealing with the question of composition of offence observed that the amount paid as compounding fee cannot be deducted from the sales tax payable by the dealer. This revision petition has been filed by the dealer against the said order passed by the tribunal. 2. The substantial question urged by the assessee is as follows: "Whether on the facts and in the circumstances of the case, the appellate Tribunal is justified in law in holding that the amount collected under S.47(1) (a) on composition of offence does not include the tax payable on the turnover suppressed or supposed to have been suppressed?" In order to appreciate the question raised by the assessee it is necessary to advert to the provisions contained in S.47(1) (a) of the Act, which runs as follows: "47. Composition of offences - (1) The assessing authority or other officer or authority authorised by the Government in mis behalf may accept from any person who has committed or is reasonably suspected of having committed an offence against this Act, by way of composition of such offence (a) Where the offence consists of the evasion of any tax payable under this Act, in addition to the tax so payable, a sum of money equal to the amount of tax so payable subject to a minimum of rupees one hundred and maximum of rupees one lakh:" In order to attract the provisions contained in sub-s.(1) of S.47 there must be a bilateral agreement between the dealer and the Department. Once the dealer has agreed for composition and the compounding fee is accordingly paid, the composition of offence is complete. What is provided in sub-section (1) (a) is the manner of fixation of the compounding fee. The above provision authorises fixing of the compounding fee at a sum of money equal to the amount of tax payable' subject to a minimum of rupees one hundred and the maximum of rupees one lakh. Such payment is over and above the 'tax payable' by the dealer. In the case of an offence consisting of evasion of tax the 'tax payable' by the dealer is the amount of tax sought to be evaded. After the composition of the offence the dealer cannot contend that the amount paid by him as compounding fee is inclusive of the tax so payable by Mm. In the case of an offence consisting of evasion of tax the 'tax payable' by the dealer is the amount of tax sought to be evaded. After the composition of the offence the dealer cannot contend that the amount paid by him as compounding fee is inclusive of the tax so payable by Mm. The words "in addition to the tax so payable" contained in clause (a) do not carry such a meaning. It appears to us, those words are included in the clause as an abundant measure, that is to say, no dealer is absolved from payment of tax sought to be evaded by reason of the payment of compounding fee. That being the position, the dealer cannot claim that the amount paid by him as compounding fee shall be deducted from the total tax due as per the assessment order. 3. In view of what is said above, the contention advanced by the dealer in Ms revision petition has no merit and it is liable to be rejected. Accordingly, we dismiss the Tax Revision case at the stage of admission.