SYED SHAH MOHAMMED QUADRI, J.

( 1 ) THE petitioner is an assessee under the Andhra Pradesh General Sales Tax Act, 1957 (for short "the Act" ). The disputed turnover for the assessment year 1985-86, which pertains to sale of refrigeration gas and coir filters, Rs. 5,12,260. 45, was assessed as relating to sale of general goods at the rate of 5 per cent by the Commercial Tax Officer on 14/10/1986. The Deputy Commissioner (CT), Punjagutta Division, in exercise of the power under section 20 (2) of the Act, revised the order of assessment after notice to the petitioner-assessee and assessed the same at the rate of 13 per cent taking the view that it is taxable under entry No. 2 of the First Schedule to the Act. The plea of the assessee that the turnover elates to gas which falls under entry No. 118 was not accepted by the revisional authority. The order of revision dated 8/07/1988 was assailed before the Sales Tax Appellate Tribunal by the petitioner-assessee. The Tribunal upheld the order of the Deputy Commissioner that the disputed turnover was taxable under item No. 2 to the First Schedule at the rate of 13 per cent; however, it also held that where the goods in question were sold fo

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