( 1 ) THE Order of the Court was delivered by the Hon ble The Chief Justice. This is an appeal against the order of our learned brother Satyanarayana raju J. in Writ Petition No. 314 of 1954.

( 2 ) THE relevant facts are stated in the judgment under appeal and they may be briefly re-stated. The appellants are a firm carrying on tannery business at Guntur. Though they had taken out a licence under Section 5 (vi) of the Madras General Sales Tax Act (hereinafter referred to as the Act) for the year 1951-52, they did not get it renewed for the subsequent years. Nor. did they submit a return of their turn-over for the year 1952-53. The Commercial tax Officer, on a scrutiny of the accounts, found that their turnover of sales of tanned hides and skins amounted to Rs. 5, 36,001-14-2. To a notice given to them to show cause against assessment on the said turnover, they contended that, as they did not take out a licence, there was no provision under the Act to tax them. Rejecting the plea, the Commercial Tax Officer made the assessment on the basis of the aforesaid turnover and called upon them to pay a tax of Rs 8,375-0-6. The appellants filed a petition under Art. 226 of the Constitution o

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