Judgment

KHANNA, J.:- These appeals by special leave are against the judgment of Madras High Court whereby that Court repelled the challenge to the validity of Items 7 (a) and 7 (b) of the Second Schedule to the Madras General Sales Tax Act, 1959 (hereinafter referred to as the State Act).

2. The appellants are dealers in hides and skins. The appellants purchase raw hides and skins locally as well as in the course of inter-State trade and commerce. The raw hides and skins are converted into dressed hides and skins and are sold either locally or in the course of export. The matter relates to the assessment year 1968-69 and the dispute between the parties arises because of the inclusion in the turnover of the sale and purchase price of some of the above goods. The appellants by means of writ petitions challenged the validity of Items 7 (A) and 7 (b) of the Second Schedule to the State Act. The High Court, as already mentioned, repelled the attack on the validity of those items and dismissed the writ petitions.

Before dealing with the contentions advanced, it may be appropriate to refer to the relevant provisions. Section 4 of the State Act is the charging section in respect of declared