Judgement

S. R. DAS, Actg. C. J.: This judgment will deposed of the four Criminal Appeals Nos. 107 to 110 of 1954.

2. These appeals have been filed by the State of Madras under certificates granted under Art. 134 (1) (c) of the Constitution by the High Court of Madras which, by its judgment in revision dated the 12th February 1954, reversed the order dated the 29th December 1952 passed by the Additional First Class Magistrate II, |Salem, and acquitted the accused.

3. The respondents are merchants dealing in hides and skins in Salem. Their business consists mainly in the purchase of hides and skins and exporting the same to foreign countries. The respondents were assessed to sales tax in different amounts on their respective turnovers of purchases of skins made by them in pursuance of orders placed with them by foreign buyers for the supply of the same .The respondents having failed to pay the entirety of the amounts of sales tax so assessed, complaints were laid against them under S. 15 (b) of the Madras General Sales Tax Act.

4. Before the Magistrate it was contended on behalf of the respondents that the purchases of skins sought to be taxed having taken place in the course of their e