( 1 ) THIS appeal is by the assessee and is directed against the order No. SMP 20/83-84 dated 16th january, 1984, of the Commissioner of Commercial Taxes, Karnataka, Bangalore ("commissioner"), made under section 22a of the Karnataka Sales Tax Act of 1957 ("kst act" ).

( 2 ) M/s. Associated Mechanical Industries, Belgaum, the assessee-appellant, a partnership firm of partners inter alia engaged in selling "gi" pipes is a registered dealer on the file of the Assistant commissioner of Commercial Taxes (Assessments), Belgaum (ACCT), under the KST Act and the Central Sales Tax Act of 1956 (CST Act ). The assessee generally purchases GI pipes from a manufacture called Gujarat Steel Tubes Limited, Ahmedabad (GST Ltd.), which has its sales office at Bangalore City. The GST Ltd. is also a registered dealer on the file of the Additional assistant Commissioner of Commercial Taxes (Assessment-I), Bangalore, under the KST Act and CST Act and on their sales to the assessee, it had paid sales tax due to the State of Karnataka under the KST Act.

( 3 ) FOR the assessment period from 1st July, 1977, to 30th June, 1978, or for the year 1977-78, the assessee filed its return before