S. ANANDA REDDY, J.

This special appeal by the assessee is directed against the order, dated January 3, 1994 passed by the Commissioner of Commercial Taxes under section 2(1) of the Andhra Pradesh General Sales Tax Act, 1957 (herein after referred to "the Act"), exercising the powers of revision, revising the order of the Appellate Deputy Commissioner of Commercial Taxes, who allowed the appeal of the assessee.

The assessee-company was dealing in fertilisers during the assessment year 1986-87. The assessee-company has got a factory at Kakinada, East Godavari district for the manufacture of various fertilisers, which commenced its production in the year 1988. But, in order to establish the market to its products, the assessee-company imported certain fertilisers, such as Di-Ammonia Phosphate (DAP), Urea, etc., and sold through its distributors. For the assessment year in question, the assessee declared a gross-turnover of Rs. 38,48,09,511 and a net turnover of Rs. 31,76,66,874. In the assessment proceedings, the assessee claimed exemption of the turnover to the extent of Rs. 1,87,89,413, being the amount represented the discount allowed to various dealers by issuing credit