JUDGMENT

The judgment of the High Court (JEEVAN REDDY and PANDURANGA RAO, JJ.) which was delivered by JEEVAN REDDY, J. was as follows :

JUDGMENT OF THE HIGH COURT

The petitioner was a registered dealer under the Andhra Pradesh General Sales Tax Act and Central Sales Tax Act having its oil mill at Kurnool. The petitioner was engaged in the business of purchasing groundnuts and manufacturing and selling groundnut oil and cake. For the assessment year, 1974-75, the petitioner was subjected to tax on the purchase turnover relating to groundnuts in a sum of Rs. 1,80,09,445. On the said turnover, tax was levied at 4-1/4 per cent. The assessment order was made on September 29, 1977. Subsequently the order was rectified and 1/4 per cent of tax was deleted by an order dated December 1, 1977, on the ground that groundnuts being declared goods, no additional tax can be levied. The proceedings thus became final. The petitioner says that the business was closed down in July, 1978. Some years later, an attempt was made to recommence the business and in that connection, the petitioner says, he met the auditor and tax consultant in the third week of January, 1984 in order to check up the sales tax