THANIKKACHALAM, J.

The assessee is the petitioner. The assessee is the dealer in dressed skins. The assessee claimed exemption on purchases in wattle extract amounting to Rs. 1, 12, 799.93, effected through the All India Skin and Hide Tanners and Merchants Association. The assessee contended that the assessee is entitled to exemption claimed in respect of purchase through the All India Skin and Hide Tanners and Merchants Association (hereinafter referred to as "the Association") in view of the certificate dated March 3, 1984, issued by the association. The assessing officer held that the abovesaid association is not an agent of the assessee and the assessee is the last purchaser and the consumer. Therefore, a sum of Rs. 1, 12, 799.93 is assessable at 2 per cent. Aggrieved with the same, the assessee filed an appeal before the Appellate Assistant Commissioner. According to the Appellate Assistant Commissioner, since the purchases could not be linked with any earlier written contract, the assessing officer was correct in levying taxes on Rs. 1, 12, 799.93, especially, according to the Appellate Assistant Commissioner when there is no evidence to show that the said associat