VISWANATHA SASTRY, J.

( 1 ) THE question that arises in these cases relates to the levy of sales tax in respect of transactions in untanned hides and skins under the Madras General Sales Tax Act and Turnover and Assessment Rules made thereunder, hereinafter referred to as "the Act" and "the Rules" respectively. Untanned hides and skins purchased by licensed dealers within the State were sent to commission agents outside and sold and exported by those agents to foreign buyers, The State spught tp levy sales tax upon the dealers in the State on the amount for which they bought the unjanned hides and skins sold and exported out of India. The dealers objected to the levy of the tax and their objection was upheld by the Sales Tax Appellate Tribunal 13 some cases but over-ruled in others. The State and the assessees have preferred revision petitions in so far as the order of the Tribunal was adverse to them. It is common ground that the assessees are licensed dealers carrying on business in hides and skins in the State, and are not exempt from taxation under section 3 (3) of the Act. The tax is sought to be levied on them as the last dealers who bought untanned hides and skins in the Sta

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