Judgment

S. K. DAS J. : These are two appeals on certificates granted by the High Court of Madras and consolidated by its orders dated March 22, 1957. They are from the judgment and orders of the said High Court dated April 20, 1956 and July 30, 1956 in two Tax Revision Cases, by which the High Court dismissed two petitions filed by the appellants under S. 12 B of the Madras-General Sales Tax Act (Madras Act IX of 1939), hereinafter called the principal Act., in the following circumstances.

2. Messrs. George Oakes (Private) Limited, appellants herein, are dealers in Ford motor cars, spare arts and accessories. For the two years 1951-52 and 1952-53 the appellants submitted their returns under the relevant provisions of the principal Act and claimed exemption from tax which regard to certain amount realised on transactions of sales which the appellants contended were inter State sales and hence exempt from tax under Art 286 of the Constitution as it stood at the relevant time. The Deputy Commercial Tax Officer, Madras, not only rejected the claim of exemption, but added to the turnover certain amounts which the appellants had collected by way of tax. The amounts so added for 1951-52 we