U.P.Singh, J.

1. By this writ application the petitioners have challenged the validity of the order contained in annexure-2 whereby reassessment proceeding has been initiated against the petitioner by the respondent No. 2 under Sec.18(1) of the Bihar Sales Tax Act, 1959. This relates to the period 1977-78.

2. The first petitioner is a company and it owns and runs a modern wheat roller flour mills and it manufactures wheat products like atta, sujji and maida. It is a registered dealer within the meaning of the Act and the second petitioner is one of the directors of the said company.

3. During the period 1977-78 this company had sold wheat products worth Rs. 13 lacs and all outside the State of Bihar through its arhatias. It claimed deduction and exemption in respect of such sales under the Act. The assessing officer, after examining each and every matter on record and after proper verification of the books of accounts, allowed the deduction claimed by the petitioner. The assessment order is dated 11th April, 1979 marked annexure-1.

4. In the year 1982, the Deputy Commissioner initiated a proceeding of reassessment and the petitioner-company was directed to produce the books