Ramaswami, J.

1. In this case the assesse, namely, the Tata Iron and Steel Company Limited, is registered as a dealer under the Bihar Sales Tax Act (Bihar Act 19 of 1947). For the period from 1-7-1947, to 31-3-1948, the Sales Tax Officer determined the gross turnover of the assessee to be Rs. 12,80,15,327/- and odd. Similarly for the period from 1-4-1948 to 31-3-1949, the Sales Tax Officer held that the gross turnover was Rs. 21,74,45,540/-, The assessee claimed before the Sales Tax Officer that the sale of goods which has been sold and delivered outside the province should not be included in the gross turnover.

The assessee also claimed that the amount of sales tax collected from the customers should not be added to the gross-turnover for the purpose of computing sales tax. As regards the first head of exemption, the assessee claimed a sum of Rs. 2,88,60,787 and odd for the first period of assessment & a sum of Rs. 10,71,66,233 & odd for the second period of assessment. Under the second head of exemption the assessee claimed that a sum of Rs. 13,66,496 and odd should be deducted for the first period of assessment and a sum of Rs. 22,37,919 and odd should be deducted for th