( 1 ) THIS appeal is directed against an order of the High court of Mysore dismissing summarily the Sales Tax Revision Petition filed by the State.

( 2 ) IT was the common case of the parties before the tribunal that the respondents turnover relating to gingelly and castor seeds became exigible to central Sales Tax by virtue of the insertion of Ss. (I-A) in Section 6 of the central Sales Tax Act, 1956, by (Amendment) Act 28 of 1969. By virtue of Section 10 of the said Amendment Act, however, the dealer was liable to pay the tax only where he had collected it, for the reason that the period concerned herein fell within what the tribunal called the protected period. (The period concerned herein is from 1/4/1968 to 31/3/1969.) The burden of proving that he has not collected the tax was, however, placed upon the dealer, by the said Amendment Act. Ss. (1 and (2 of Section 10 of the said Amendment Act read thus:"10. (1 Where any sale of goods in the course of inter-State trade or commerce has been effected during the period between the 10th day of November, 1964 and the 9th day of June, 1969 and the dealer effecting such sale has not collected any tax under the principal Act on the groun