B. PRAKASH RAO, J.

The State filed this revision under section 22(1) of the Andhra Pradesh General Sales Tax Act assailing the correctness of the judgment in T.A. No. 526 of 1996 dated November 4, 1996 on the file of the Sales Tax Appellate Tribunal, A.P., at Hyderabad.

Few facts necessary for disposal of this revision are that the respondent herein is sought to be levied with sales tax for disputed turnover which pertains to the business as a dealer in leasing out the advertisement boards. The respondent claims that the gross turnover of Rs. 1,57,84,590 for the year 1992-93 and Rs. 1,94,10,990 for the year 1993-94 was claimed as exemption on the ground that at various places leases of landed property were taken and the customer is paying the hire charges on such boards, that the municipality has erected the hoardings and the said hoardings are being let out by the dealer to various parties for a consideration. Initially, the Commercial Tax Officer held that there was no sale of goods as the boards/hoardings are permanently fixed to earth and it constitutes immovable property and it does not come within the parameters of section 5E of the said Act and granted exemption. Later