CHINNAPPA REDDY, J.

( 1 ) THE petitioner is a firm carrying on business in the purchase of groundnuts, decorticating of groundnut into kernel and sale of kernel to millers or other dealers or export of outside the State of Andhra Pradesh. The firm owns no equipment for crushing the kernel in top oil and does not engage itself in the business of crushing kernel into oil. During the assessment years 1961-62 and 1962-63 the petitioner was assessed to sales tax on turnovers which included amounts representing the first purchases of groundnuts were sold to millers or other dealers after decorticating. The Commercial Tax Officer included these amounts on the ground that a person working as decorticates is a miller within the meaning of Item 3 of Schedule IV of the Andhra General Sales Tax Act as it stood during that period. Appeals preferred by the petitioner to the Assistant Commissioner were dismissed and thereafter the petitioner instead of preferring appeal to the Sales Tax Appellate Tribunal has filed the present application for the issue of writs of certiorari to quash the orders of assessment. The ground alleged for circumventing the procedure of preferring appeals to the Tribunal

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