JAGANNATHA SHETTY, J.

( 1 ) THIS appeal is directed against the order of the Commissioner of Commercial Taxes made under his suo motu revisional power, reversing the order of the Deputy Commissioner of commercial Taxes (Appeals), Bangalore.

( 2 ) THE matter arises in this way : the appellant - a partnership firm - is a dealer registered under the Karnataka Sales Tax Act, 1957. It carries on business in purchase and sale of foodgrains. For the assessment year 1971-72 it submitted a return of taxable turnover of Rs. 16,27,401. 96 claiming certain exemptions and deductions in respect of containers (gunny bags) and the consignment of sale of foodgrains not taxable under section 6 of the Act. But the assessing authority did not allow the exemptions on both the points. He assessed the turnover with the addition of the following :

(a) Rs. 1,37,000 being the turnover of containers (gunny bags) in which sugar had been filled and sold by the assessee. (b) The turnover of rice and wheat products amounting to Rs. 9,01,907. 62 taxable under section 6 of the Karnataka Sales Tax Act.

( 3 ) THE assessee appealed to the Deputy Commissioner and contended that the above additions were not warranted

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