JUDGMENT V. K. SINGHAL, J. - The contention raised in the present petition is regarding inclusion of trade discount and stock transfer for the purpose of levy of turnover tax under section 6-B of the Karnataka Sales Tax Act, 1957. So far as the question of turnover tax on trade discount is concerned, the matter is covered by the decision given by this Court in the case of Belgaum Structural Engineering Pvt. Limited v. Additional Commissioner of Commercial Taxes [1998] 111 STC 222. 2. Regarding inclusion of stock transfer, it is contended that total turnover as referred under section 6-B has been defined under section 2(1)(u-2) which is the aggregate turnover. "Turnover" as defined under section 2(1)(v) is the aggregate amount for which goods are bought or sold or supplied or distributed or delivered or otherwise disposed of in any of the ways referred to in clause (t). Section 2(1)(t) refers to sale. But stock transfer is not included under either of these sections and therefore cannot be considered to be the total turnover for the purpose of liability of tax. Rule 6 prescribes the manner for determination of total and taxable turnover. Stock transfer by the assessee to his agent or branch has neither been included in the total turnover nor in the turnover. Section 6-B which is the charging section makes a dealer liable to pay tax on total turnover. The words "total turnover" as stated above refers to aggregate turnover in all goods at all places in the State. Section 6 prescribes levy of purchase tax in certain circumstances and dispatch of goods outside the State except as a direct result of sale or purchase in the course of inter-State trade or commerce is liable to pay tax on the purchase price of such goods at the same rate at which it would have been liable on the sale price of such goods under section 5. The purchase price is the turnover of purchase whether or not it is liable to tax. Rule 6 of the Karnataka Sales Tax Rules, 1957 provides for determination of total and taxable turnover. 3. Whether or not the whole or any portion of such turnover is liable to tax including the turnover of purchase or sale is to be examined. The purchase price is the turnover of purchase whether or not it is liable to tax. Rule 6 of the Karnataka Sales Tax Rules, 1957 provides for determination of total and taxable turnover. 3. Whether or not the whole or any portion of such turnover is liable to tax including the turnover of purchase or sale is to be examined. In the case of stock transfer there is no sale and therefore it cannot be included in the sale turnover but there may be purchase of goods which are liable to purchase tax. 4. Section 6-B of the Karnataka Sales Tax Act, 1957 provides for levy of turnover tax. Every registered dealer is liable to got himself registered whose turnover in a year is not less than Rs. 5 lakhs and whether or not the whole or any portion of such turnover is liable to tax under any other provisions of the said Act he is liable to pay turnover tax. According to this section there should be a turnover which may or may not be liable to tax. The words "total turnover" used in section 6-B is for the purpose of fixing the liability of turnover tax. The total turnover has been defined under section 2(1)(u-2) by which the aggregate turnover in all the goods is taken into consideration. The turnover may be of purchase or sale or it may or may not be liable to tax. The turnover under section 2(1)(v) is as under - "'Turnover' means the aggregate amount for which goods are bought or sold, or supplied or distributed or delivered or otherwise disposed of in any of the ways referred to in clause (t) by a dealer, either directly or through another, on his own account or on account of others, whether for cash or for deferred payment or other valuable consideration." The first part of the definition makes liability of tax if the goods are bought or sold. There may be purchase of goods which are liable to tax or may not be liable to tax but form part of the turnover, purchase price of such goods would be liable to turnover tax. Similarly, when there is a sale, then whether it is liable to tax or not, turnover of such goods has to be considered for the purpose of liability of turnover tax. Similarly, when there is a sale, then whether it is liable to tax or not, turnover of such goods has to be considered for the purpose of liability of turnover tax. The second part of the definition refers to "supplied or distributed or delivered or otherwise disposed of in any of the ways referred to in clause (t)". Clause (t) has given the definition of "sale". In the definition, transfer of property in any goods involved in execution of work, delivery of goods under him purchase, transfer of the right to use any goods for any purpose and transfer otherwise than in pursuance of a contract of property in any goods are included in the definition. The words "supplied, distributed, delivered or otherwise disposed of" in section 2(i)(v) take colour from the words "in any of the ways referred to in clause (t)" and therefore if such supplies, distribution, delivery or otherwise disposed of, goods falls in the definition of "sale" as given under section 2(1)(t), it would be liable to turnover tax. There may be a transfer of goods after purchasing the same in the State of Karnataka to the branch or agent outside the State in the same form that would be liable to turnover tax. But in a case when goods have been manufactured and there is no purchase or sale turnover in respect of those goods or raw material used thereof, then there is no liability of turnover tax. 5. The learned Government Advocate has relied upon a decision given in S. N. Guggari and Company v. Commissioner of Commercial Taxes in Karnataka [1998] 110 STC 426 (Kar) where sale by commission agent on behalf of outside members was held not liable to be deducted for the purpose of computation of total turnover. In that case there was turnover by commission agent of sale and therefore the deductions provided under rule 6 was held not applicable. The judgment therefore does not solve the controversy raised in the present case. Since the raw material purchased by the petitioner and used for the manufacture of goods do not form part of the turnover and there is no sale in respect of the goods transferred to the branch, the turnover tax under section 6-B cannot be levied. 6. Assessing authority shall recompute the total liability of turnover tax in the light of the observations made above. 6. Assessing authority shall recompute the total liability of turnover tax in the light of the observations made above. Petition stands disposed of with the above observations. Petition disposed of accordingly.