SATYANARAYANA RAJU, J.

This is a revision filed by the assessees against the decision of the Sales Tax Appellate Tribunal in T.A. No. 225-A of 1953.

The petitioners are a firm of dealers in kirana articles at Eluru. They have two departments of trade, one wholesale and the other partly wholesale and partly retail. For the year of assessment 1952-53, they submitted a total turnover of Rs. 6,35,122, made up of Rs. 1,44,442 from the wholesale department and Rs. 4,90,680 from the partly wholesale and partly retail department. The petitioner's shop was inspected by the Special Assistant Commercial Tax Officer and he found that all the sales were not brought into account. He discovered three sales written on slips of paper in the year 1952-53, which did not find a place in the accounts. For the year 1953-54, he found that such sales written on slips of paper, but which were not brought into account, were more than 70 in number. A notice was issued that the net turnover would be determined to the best of judgment. The petitioners sent their reply to the notice. After the reply was received, it was considered and the Deputy Commercial Tax Officer, in his order of assessment, determin