Judgement

SABYASACHI MUKHARJI, J. :- This appeal by special leave arises from the Judgment and order dt. 14th Dec. 1972 of a Bench decision of the High Court of Andhra Pradesh in Writ Petn. No. 3464 of 1971, (reported in 1973 Tax LR 2590).

2. The Division Bench dismissed the application under Art. 226 of the Constitution filed by the appellant. The appellant was a tanner who had his tannery at Vizianagaram and was at the material time a dealer under Andhra Pradesh General Sales Tax Act, 1957 as well as the Central Sales Tax Act, 1956, hereinafter called the State Act and the Central Act respectively. The appellant purchases raw hides and skins in the State of Andhra Pradesh and tan the same. The appellant used mostly to sell such tanned hides mostly to sell such tanned hides in the course of inter- State trade.

3. The first respondent i.e. the Commercial-tax Officer, Vizianagaram, by his order dated 30th January, 1969 had assessed the appellants inter-State sales turnover at Rs. 16,23,194.29 and levied a tax of Rs. 48,695.82 under the Central Act. The local purchase turnover of raw hides was assessed at Rs. 7,92,585/- and a tax of Rs. 23,777.66 was also levied.

4. The appellant had fil