DR. A. S. ANAND, C.J.

These two tax revisions relate to the assessment years 1975-76 and 1976-77 and since common questions of law and fact are involved, the same are being disposed of by this common order.

2. The petitioner is the assessee, who is a dealer in high density polythene woven sacks. For the assessment year 1975-76, it was assessed under the Tamil Nadu General Sales Tax Act, 1959 (hereinafter referred to as "the Tamil Nadu Act) on a total taxable turnover of Rs. 23, 48, 630.92 by the Joint Commercial Tax Officer, vide his assessment order dated January 4, 1977. In this order, exemption was allowed on a sum of Rs. 6, 72, 861.47 on production of E1 form under section6(2) of the Central Sales Tax Act, 1956 (hereinafter referred to as the Central Act'), on sale of goods effected in the course of inter-State movement. It transpires that the premises of the petitioner-industry was inspected by the officers of the Inter-State Investigation Cell on August 7, 1978. The inspection revealed that the exemption granted on a sum of Rs. 6, 72, 861.47, as sales effected in the course of inter-State movement of goods from one State to another was not in order and that the sale