JUDGMENT

V. RAMASWAMI, J. :- Special leave granted.

2. The appellant is a registered dealer under the Karnataka Sales Tax Act (hereinafter called the Act). The appellant (hereinafter referred to the assessee) purchases iron scrap from dealers inside and outside the State of Karnataka for the purpose of manufacturing iron ingots, steel rounds and torsteel. These manufactured goods were sold mostly within the State. In respect of the Assessment Years 1972-73 to 1974-75, accepting the contentions of the assessee that the goods sold were manufactured out of tax suffered iron scrap, the Commercial Tax Officer exempted the sales turn-over of the manufactured goods. The Deputy Commissioner of Commercial Taxes in exercise of his powers under section 21 of the Act restricted the exemptions but otherwise confirmed the assessment order by his order dated 11-5-1979. The respondent Commissioner of Taxes, Bangalore initiated proceedings under section 22 (A) of the Act for revising the order of the Deputy Commissioner on the ground that the assessee had been allowed exemption in respect of the turn-over of manufactured goods without verifying as to whether the inputs iron scrap had suffered taxes a