GOPAL RAO EKBOTE, C.J. - This revision petition is from the order of the Sales Tax Appellate Tribunal Andhra Pradesh, given in Tribunal Appeal No. 778 of 1970 on 26th September, 1972.

The essential facts are that the petitioners are dealers in liquors, cigarettes, etc., and also are ship-chandlers. They submitted returns of their turnover for the year 1967-68 showing Rs. 2,19,972.82 as gross turnover and Rs. 97,462.58 as net turnover. They claimed exemption on transactions totalling Rs. 1,22,510.24. The said claim included Rs. 72,061.69 comprising of sales of "bonded warehouse ship-stores". According to the petitioners, the ship-stores were imported from foreign countries, kept in bonded warehouses of the customs department and later sold and delivered to ships' masters for consumption aboard the ships. They claimed that such sales were not exigible to tax under the Andhra Pradesh General Sales Tax Act, 1957, hereinafter called the Act, being sales outside the State of Andhra Pradesh. In the reply, which the petitioners gave on 29th January, 1969, to the pre-assessment notice dated 16th January, 1969, they set up their claims as follows :

"We procure the ship-store goods f