SATYANARAYANA RAJU, J.

This revision case arises out of an order of the Sales Tax Appellate Tribunal rejecting the petitioner's appeal, T.A. No. 394 of 1957.

The petitioner is a dealer at Vijayawada. His main business during the year of assessment 1953-54 consisted in purchasing raw skins and hides at Vijayawada and exporting them to tanners at Madras.

Under section 3(1) of the Madras General Sales Tax Act, 1939, every dealer is liable to pay for each year a tax on his total turnover for such year. Section 5, however, grants certain exemptions and reductions of tax in certain cases, subject to such restrictions and conditions as may be prescribed, including the conditions as to licence and licence fees. Under section 5, clause (vi), the sale of hides and skins, whether tanned or untanned, is liable to tax only at such single point in the series of sales by successive dealers as may be prescribed. Rule 16 of the Madras General Sales Tax (Turnover and Assessment) Rules, 1939, prescribes that in the case of hides and skins the tax payable under section 3(1) shall be levied in accordance with the provisions of that rule. Under sub-rule (2) no tax shall be levied on the sale of