JUDGMENT

S.B. Sinha, J. —

1. Leave granted.

2. Appellant, Haleema Zubair, is an assessee under the Kerala General Sales Tax Act, 1963 (for short ‘the Act’). She is said to be the proprietress of two concerns, - one known as M/s. Tropical Traders and another M/s. Poseidon Food Company.

3. The said Topical Traders is a dealer in ceramic tiles. The business of M/s. Poseidon Food Company was to render services to various exporters as regards inspection and certification of quality of the items sought to be exported. The total turnover for the purpose of payment of sales tax was disclosed on the basis of the business carried out in the name of M/s. Tropical Traders. Whereas the taxable turnover was shown as 28,20,474.97, an addition of Rs.45,80,168.09 thereto was made by the Assessing Authority assessing a sum of Rs.3,58,87,960.97 by way of total turnover. The order of assessment proceeded on the basis that receipt shown as commission amounting to Rs.45,80,168.09 from M/s. Poseidon Food Company is not supported and proved by any documentary evidence. Appellant contended that the services so rendered is not a ‘sale’ and thus, the said order of assessment is wholly illegal and without jur