( 1 ) AS the two writ petitions raised common points, it is proposed to dispose of them by a common judgment. The two points raised arc: (i) Whether livesiock fall under goods wjthin the meaning of sec. 2 (h) of the Andhra Pradesh general Sales Tax Act; (ii) Whether the petitioners are entitled for the exemption contemplated under G. O. Ms. No. 2193 Revenue dated 19-12-1961.

( 2 ) THE petitioners in both the writ petitions are dealers in goafs and sheep. For the assessment year 1969-/0. the respondent in W. P. 4419/72 Deputy commercial Tax Officer accepted the return filed by the petitionertherein and assessed him on a purchase turnover of rs. 2,43,487-75 Ps. in goats and sheep.

( 3 ) THE petitioner in W. P. 5225/72 is a dealer in goats and sheep at Kodavaluru. His business consists in purchasing locally livestock such as goats and sheep and selling them to dealers at madras who in their turn sell them to butchers in Madras. For the year 1968- 69, the Commercial Tax Officer, Nellore by his assessment order dated 9-5-1969 assessed the petitioner to tax on a net purchase turnover of Rs. 3,75,087-00 as against the purchase turnover of Rs. 3,40,839/- disclosed by the ac